1. INTRODUCTION

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.

1.2 MNGM/Platform Provider is committed to protect the Customer’s privacy and grant importance to the confidentiality of the Customer’s information over the internet. This Privacy Policy shall apply to the Customer using or accessing any or all products, services, features, or content offered on the Platform.

1.3 By using and accessing the Services, the Customer is consenting to the practices described in this Privacy Policy. This Privacy Policy does not require any physical, electronic, or digital signature and is a legally binding document between the Customer and the MNGM.

2. GENERAL

2.1 In this Privacy Policy, Personal Information means any information that relates to a natural person, which, either directly or indirectly, or in combination with other information available or likely to be available, is capable of identifying such person. Some of this information may be categorized as Sensitive Personal Information such as the financial information including but not limited to: bank accounts, or other payment instrument details.
Personal Information and Sensitive Personal Information shall be collectively referred to as (“Personal Data”).

2.2 This Privacy Policy describes how MNGM, and its Affiliate, collect and process the Customer Personal Data through the Platform and performance of Services. MNGM collects and utilize the Customer Personal Data only to enhance, maintain, protect, improve the Services (including advertising services, if applicable) and operation of the Platform, to allow the Customer to use all the listed features, and to allow MNGM to respond to the Customer’s Request. Certain Personal Information is used for the purpose of system administration or for statistical or backup purposes; other Personal Data is used strictly in line with the purpose of improving the Platform and the Services offered over the Platform, as clarified under point (3). MNGM will not use, process, or transfer these Personal Data beyond the limits permitted under this Privacy Policy and the Terms.

2.3 By providing MNGM the Customer’s Personal Data or by downloading and using the Platform, the Customer expressly gives MNGM consent to collect, store, process, use & disclose the Customer’s Personal Data in accordance with this Privacy Policy. If the Customer does not agree to the terms of this Privacy Policy, the Customer should not use or access the Services provided by the Platform.

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.

2.5 The Customer acknowledges that this Privacy Policy, together with Terms, forms MNGM’s agreement with the Customer in relation to his/her use of the Platform. Click here to read the Terms.

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.
  1. Information and documents regarding identity, including national ID number, and passport.
  2. Other documents needed as a proof of identity or address for KYC processes.
  3. Financial data, including bank account details.
  4. Location information, including time zone, postal address, and location details, to provide the Customer better & prompt customer service; and
  5. Personal information stored with third parties if the Customer chooses to provide such information to MNGM, including the Customer’s social media account information and the social media contacts. By linking the Customer’s third-party accounts or using third party sign-in services, the Customer authorizes MNGM to have access to this information and the Customer agrees that MNGM may collect and use this information only in accordance with this Privacy Policy, if applicable.

• 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):
  1. IP addresses used to connect the Customer’ computer to the internet;
  2. Domain Servers;
  3. The location of the Customer’s device or computer;
  4. Other information with respect to the Customer’s device, operating system, interaction of the Customer’s device with the Platform.
  5. Information from the Customer’s device, which may include  application usage, connectivity data, and any errors or event failures;
  6. Purchase and content use history;
  7. The URL clickstream to through and from the Platform, including date and time, and products and content the Customer viewed or searched for;
  8. 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.

3.2 All information is stored or used for processing orders and under no circumstance are any of these details made available in the public domain. However, MNGM may use such information to share with the Customer additional and/or upcoming information regarding the services and features of the Platform in accordance with this Privacy Policy.

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. COOKIES

5.1 To enable MNGM systems to recognize the Customer’s browser or device and to provide and improve the Platform and/or the Services, MNGM uses cookies and other identifiers to collect information to assign each Customer a unique Identification to understand the Customer’s individual interests using the identified computer. A “cookie” is a small piece of information stored by a web server on a web browser so it can be later read back from that browser.

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.

5.5 MNGM uses cookies to recognize the Customer’s browser or device, learn more about the Customer’s interests, and provide the Customer with essential features and services and for additional purposes, including:

• 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.

5.7 Approved third-parties may also set cookies when the Customer interacts with Platform and Services. Third parties include search engines, providers of measurement and analytics services, social media networks, and advertising companies. Third-parties use cookies in the process of delivering content, including ads relevant to the Customer’s interests, to measure the effectiveness of their ads, and to perform services on behalf of MNGM.

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.

6.2 MNGM shares Customers' Personal Data only in the following limited circumstances with third-parties/Service Providers which are subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy:

• 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;
• In case of business development where MNGM might sell/buy other business or services. In such transactions, Customer Personal Data generally is one of the transferred business assets, yet it remains subject to the promises made in this Privacy Policy, unless the Customer consents otherwise;
• With MNGM’s Affiliate  and officers and employees of such Affiliate for the purpose of processing Personal Data on MNGM behalf. MNGM also ensures that these recipients of such Personal Data agree to process same based on MNGM instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures;
• 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: hello@mngm.com

7. LINKS TO THIRD PARTY SITES

7.1 The Platform may contain links to third-party websites or applications. Third-party advertising partners may collect information about the Customer when the Customer interact with their content, advertising, and services. The Customer agrees and understands that privacy policies of these websites are not under MNGM control. The Customer understands that once he/she leaves MNGM servers, the use of any information/Personal Data provided by the Customer shall be governed by the privacy policy of the operator of the site used by him/her.

7.2 When the Customer accesses another website through a link or a URL available on the Platform, this Privacy Policy does not apply anymore. MNGM shall in no way be responsible in any way for the Customer’s use of such sites. MNGM are not responsible for the content, or the privacy polices of third-party websites.

8. SECURITY

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.

8.4 Although MNGM makes best possible efforts to store Personal Data in a secure operating environment that is not open to the public, the Customer must understand that there is no such thing as complete security, and MNGM do not guarantee that there will be no unintended disclosures of Personal Data. If MNGM becomes aware that the Customer Personal Data has been disclosed in a manner not in accordance with this Privacy Policy, MNGM will use reasonable efforts to notify the Customer of the nature and extent of such disclosure as soon as reasonably possible and as permitted by law.

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 hello@mngm.com. MNGM’s support centers are operative throughout the weekday between 9am and 5pm (subject to public holidays).

11. DISCLAIMER

MNGM will comply with the Egyptian data protection law (“Law”) no. 151 of 2020 upon the lapse of the grace period set out under such Law. Nothing in this Privacy Policy grants any rights to the Customer or imposes any obligations on MNGM regarding protection of Personal Information, pursuant to the provisions of the aforementioned Law, up until the lapse of the grace period set out under the law.