1.1 Terms used but not defined herein shall have the meanings given to them in the Terms and will be in bold for the first use.
Personal Information and Sensitive Personal Information shall be collectively referred to as (“Personal Data”).
2.4 MNGM respects the privacy of the Customer and is committed to protect it in all respects. Personal Data about the Customer which is collected by MNGM include: (i) information supplied by the Customer; (ii) information automatically tracked during the Customer’s navigation on the Platform; and/or (iii) information provided by third-parties in order to perform the Services. Other information may be collected, such as information for which the Customer has given consent for the processing of such information, or for compliance with a legal obligation to which MNGM is subject to.
3. INFORMATION COLLECTED
3.1 MNGM collects the Customer’s Personal Data in order to provide and continually improve the Platform and the Services over the Platform. Below are the types of Personal Data MNGM collects:
- Provided Information: Before the Customer can use the Services through the Platform, MNGM may require the Customer to provide MNGM with some information. This information is collected for the purpose of performing the Services. The following information may be required when the Customer creates the Gold Profile:
- Contact data, including name, address, email address, phone number, and date of birth.
- Information and documents regarding identity, including national ID number, and passport.
- Other documents needed as a proof of identity or address for KYC processes.
- Financial data, including bank account details.
- Location information, including time zone, postal address, and location details, to provide the Customer better & prompt customer service; and
- Automatic Information: By browsingthe Platform, the Customer’s acknowledges and accepts that MNGM automatically collects and stores certain types of information about the Customer’s use of Services. This information is collected for the purpose of MNGM system administration, or for statistical or backup purposes. Like many websites, MNGM uses "cookies" and other unique identifiers as clarified under point (5. Cookies) of this Privacy Notice. When the Customer’s web browser or device accesses the Platform, MNGM obtains the following types of information (including but not limited to):
- IP addresses used to connect the Customer’ computer to the internet;
- Domain Servers;
- The location of the Customer’s device or computer;
- Other information with respect to the Customer’s device, operating system, interaction of the Customer’s device with the Platform.
- Information from the Customer’s device, which may include application usage, connectivity data, and any errors or event failures;
- Purchase and content use history;
- The URL clickstream to through and from the Platform, including date and time, and products and content the Customer viewed or searched for;
- Page response times, download errors, length of visits to certain pages, and page interaction information including scrolling, clicks, and mouse-overs; and
- Information from third-parties: Using the Services may require the assistance of Service Providers. For any services that the Customer may use, MNGM might receive information about the Customer from other third-parties. MNGM collects the Personal Data that is necessary for the delivery of the Services, and/or for the performance of a contract for which the Customer is a party.
4. RETENTION & DELETION OF PERSONAL DATA
4.1 MNGM understands its legal duty to retain accurate information, and MNGM only retains Personal Data for as long as it needs it for the purpose for which MNGM collected such Personal Data or as legally mandated.
4.2 Retaining Personal Data will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. MNGM may retain the Customer’s Personal Data to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, enforce the Terms, and take other actions as permitted by law and as required to provide the service.
4.3 Once the purpose is satisfied or the legally mandated period has expired, MNGM will securely delete the Customer’s Personal Data.
5.2 Cookies is not a tool to identify the Customer. Unless the Customer voluntarily identify him/herself, through registration for example, MNGM will have no way of knowing who the Customer is, even if MNGM assign a cookie to the Customer’s computer.
5.3 The only Personal Information a cookie can contain is information the Customer’s supply. A cookie cannot read data off the Customer’s hard drive. Cookies cannot be used to run programs or deliver viruses to the Customer’s computer.
5.4 MNGM receives and stores certain types of information whenever the Customer’s interact with MNGM via the Platform or the Services through the Customer’s computer/laptop/netbook or mobile/tablet/pad/handheld device.
- Recognizing the Customer when he/she sign-in to use the Services. This allows MNGM to provide the Customer with product recommendations, display personalized content, and provide other customized features and services;
- Keeping track of the Customer’s specified preferences. This allows MNGM to honor the Customer’s preferences, such as whether or not the Customer would like to see interest-based ads;
- Keeping track of items stored in the Customer’s shopping basket;
- Conducting research and diagnostics to improve the Platform and/or Services;
- Preventing fraudulent activity;
- Improving security;
- Delivering content, including ads, relevant to the Customer’s interests on the Platform and third-party sites; and
- Measuring and analyzing the performance of the Platform and Services.
5.6 Blocking or otherwise rejecting MNGM cookies, may limit the Customer’s usage of some of the Platform features.
5.8 The Customer can manage browser cookies through the Customer’s browser settings. The 'Help' feature on most browsers will tell You how to prevent the browser from accepting new cookies, how to have the browser notifies when the Customer receives a new cookie, how to block cookies, and when cookies will expire. If the Customer blocks all cookies on the browser, neither MNGM nor third-parties will transfer cookies to that browser. If the Customer does this; however, the Customer may have to manually adjust some preferences every time the Customer visits a website, and some features and services may not work.
6. DISCLOSURE AND INFORMATION SHARING
6.1 Information about MNGM’s Customers is an important part of MNGM’s business. MNGM will not sell MNGM’s Customers' Personal Data to others.
- When the Customer’s transaction requires using any service that requires the assistance of a Service Provider, such as fulfilling orders, delivering and vaulting the Customer Gold, processing payments, providing marketing assistance, and providing customer service;
- When it is requested or required by law or by any court or governmental entity or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosures are reasonably necessary for enforcing the Terms, and for complying with the applicable laws and regulations.
6.3 MNGM shall take all reasonable steps to ensure that the confidentiality of the Customer’s Personal Data is maintained by imposing strict confidentiality standards on all the third-parties with whom MNGM parts this Personal Data. In all circumstances, MNGM shall ensure that the Customer’s Personal Data is protected by strict confidentiality agreement.
6.4 MNGM does not disclose the Customer’s Personal Data to any advertisers or any third-party for their marketing and advertising purposes without the Customer’s explicit consent.
6.5 MNGM may use the Customer’s Personal Data to display relevant promotions and marketing offers, based on their preferences. To the extent that MNGM may use the Customer’s Personal Data to market to the Customer, MNGM will provide the Customer the ability/right to opt-out of such uses at any time, directly by clicking on the unsubscribe link available on each email received, by modifying the Gold Profile settings, or by contacting MNGM at the following email address: firstname.lastname@example.org
7. LINKS TO THIRD PARTY SITES
8.1 MNGM follows generally accepted industry standards to protect the Personal Data submitted to MNGM, both during transmission and once MNGM receives it. All Personal Data gathered on MNGM Platform is securely stored within MNGM controlled database. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited.
8.2 This Personal Data is immediately deleted once the Customer deletes his Gold Profile, except to the extent that it is necessary to store the information under applicable laws.
8.3 We have implemented commercially reasonable physical, managerial, operational and technical security measures to protect the loss, misuse and alteration and to preserve the security of the Personal Data in MNGM’s care.
8.5 It is important for the Customer to be protected against unauthorized access to the Customer’s password and to the Customer’s computers, devices, and applications. MNGM recommends using a unique password for the Gold Profile that is not used for other online accounts. The Customer should be sure to sign off when finished using a shared computer.
9. REVIEWING AND UPDATING PERSONAL DATA
The Customer can access and change the Personal Data and preferences provided when Gold Profile is created through the Gold Profile page or by contacting MNGM. Without prejudice to the provisions of the Terms, MNGM shall ensure that any Personal Data found to be inaccurate or deficient to be corrected or amended as feasible.
10. CONTACT US
If the Customer has any questions, comments or concerns about MNGM privacy practices or would like to provide feedback on the Services offered on the Platform, please contact MNGM at email@example.com. MNGM’s support centers are operative throughout the weekday between 9am and 5pm (subject to public holidays).