1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, "we", "us" and "our" refer to Mvine Ltd. For more information about us, see Section 10.
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process.
2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer. If you log into our website using a social media account, we will obtain elements of the contact datafrom the relevant social media account provider.
2.3 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication.
2.4 We may process information relating to our customer relationships("customer relationship data"). The customer relationship data may include your name, the name of your business or employer, your job title or role, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you, or between us and your employer. The source of the customer relationship data is you and/or your employer, should you wish to provide this to us when in communication with us .
2.5 We may process data about your use of our website and services("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google analytics.
2.6 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Publications - We may process account data, profile data and/or service data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.
3.3 Relationships and communications - We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
3.4 Direct marketing - We may process contact data, account data, profile data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent.
3.5 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.6 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.7 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.8 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Retaining and deleting personal data
4.1 This Section 4 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3 We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 3 monthsfollowing the date of the most recent contact between you and us, and for a maximum period of 12 months following that date;
(b) customer relationship data will be retained for a minimum period of 3 months following the date of termination of the relevant customer relationship and for a maximum period of 12 months following that date;
(c) communication data will be retained for a minimum period of 3 months following the date of the communication in question, and for a maximum period of 12 months following that date; and
(d) usage data will be retained for 12 months following the date of collection.
4.4 Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. Security of personal data
5.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
5.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
5.3 The following personal data will be stored by us in encrypted form: the name you gave us when you used our contact form; the email you gave us when you used our contact form; the telephone number you gave us when you used our contact form; any additional contact information you gave us when you used our contact form.
5.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
6. Your rights
6.1 In this Section 6, we have listed the rights that you have under data protection law.
6.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
6.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
6.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
7. Third party websites
7.1 Our website includes hyperlinks to, and details of, third party websites.
7.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
8. Updating information
8.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
9.1 We may update this policy from time to time by publishing a new version on our website.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
10. Our details
10.1 This website is owned and operated by Mvine Limited.
10.2 We are registered in England and Wales under registration number 05313963, and our registered office is at Downsview House, 141-143 Station Road East, Oxted, Surrey, RH8 0QE.
10.3 Our principal place of business is at Downsview House, 141-143 Station Road East, Oxted, Surrey, RH8 0QE.
10.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using the email address published on our website.
11. Data protection registration
11.1 We are registered as a data controller with the UK Information Commissioner's Office.
11.2 Our data protection registration number is Z2241124.
12. Data protection officer
12.1 Our data protection officer's contact details are: email@example.com for the attention of Sabina Nenkova .
Terms and conditions of use
1.1 These terms and conditions shall govern your use of our website.
1.2 By using our website, you accept these terms and conditions in full; accordingly, if you disagree with these terms and conditions or any part of these terms and conditions, you must not use our website.
1.3 If you submit any material to our website or use any of our website services, we will ask you to expressly agree to these terms and conditions.
1.4 You must be at least 18 years of age to use our website; by using our website or agreeing to these terms and conditions, you warrant and represent to us that you are at least 18 years of age.
2. Copyright notice
2.1 Copyright (c) 2021 Mvine Limited.
2.2 Subject to the express provisions of these terms and conditions:
(a) we, together with our licensors, own and control all the copyright and other intellectual property rights in our website and the material on our website; and
(b) all the copyright and other intellectual property rights in our website and the material on our website are reserved.
3. Permission to use website
3.1 You may:
(a) view pages from our website in a web browser;
(b) download pages from our website for caching in a web browser;
(c) print pages from our website for your own personal and non-commercial use, providing that such printing is not systematic or excessive;
(d) stream audio and video files from our website using the media player on our website; and
(e) use our website services by means of a web browser,
subject to the other provisions of these terms and conditions.
3.2 You may only use our website for your own personal and business purposes; you must not use our website for any other purposes.
3.3 Except as expressly permitted by these terms and conditions, you must not edit or otherwise modify any material on our website.
3.4 Unless you own or control the relevant rights in the material, you must not:
(a) republish material from our website (including republication on another website);
(b) sell, rent or sub-license material from our website;
(c) show any material from our website in public;
(d) exploit material from our website for a commercial purpose; or
(e) redistribute material from our website.
3.5 We reserve the right to suspend or restrict access to our website, to areas of our website and/or to functionality upon our website. We may, for example, suspend access to the website during server maintenance or when we update the website. You must not circumvent or bypass, or attempt to circumvent or bypass, any access restriction measures on the website.
4. Misuse of website
4.1 You must not:
(a) use our website in any way or take any action that causes, or may cause, damage to the website or impairment of the performance, availability, accessibility, integrity or security of the website;
(b) use our website in any way that is unlawful, illegal, fraudulent or harmful, or in connection with any unlawful, illegal, fraudulent or harmful purpose or activity;
(c) hack or otherwise tamper with our website;
(d) probe, scan or test the vulnerability of our website without our permission;
(e) circumvent any authentication or security systems or processes on or relating to our website;
(f) use our website to copy, store, host, transmit, send, use, publish or distribute any material which consists of (or is linked to) any spyware, computer virus, Trojan horse, worm, keystroke logger, rootkit or other malicious computer software;
(g) impose an unreasonably large load on our website resources (including bandwidth, storage capacity and processing capacity);
(h) decrypt or decipher any communications sent by or to our website without our permission;
(i) conduct any systematic or automated data collection activities (including without limitation scraping, data mining, data extraction and data harvesting) on or in relation to our website without our express written consent;
(j) access or otherwise interact with our website using any robot, spider or other automated means, except for the purpose of search engine indexing;
(k) use our website except by means of our public interfaces;
(l) violate the directives set out in the robots.txt file for our website;
(m) use data collected from our website for any direct marketing activity (including without limitation email marketing, SMS marketing, telemarketing and direct mailing); or
(n) do anything that interferes with the normal use of our website.
4.2 You must ensure that all the information you supply to us through our website, or in relation to our website, is true, accurate, current, complete and non-misleading.
5. Limited warranties
5.1 We do not warrant or represent:
(a) the completeness or accuracy of the information published on our website;
(b) that the material on the website is up to date;
(c) that the website will operate without fault; or
(d) that the website or any service on the website will remain available.
5.2 We reserve the right to discontinue or alter any or all of our website services, and to stop publishing our website, at any time in our sole discretion without notice or explanation; and save to the extent expressly provided otherwise in these terms and conditions, you will not be entitled to any compensation or other payment upon the discontinuance or alteration of any website services, or if we stop publishing the website.
5.3 To the maximum extent permitted by applicable law and subject to Section 6.1, we exclude all representations and warranties relating to the subject matter of these terms and conditions, our website and the use of our website.
6. Limitations and exclusions of liability
6.1 Nothing in these terms and conditions will:
(a) limit or exclude any liability for death or personal injury resulting from negligence;
(b) limit or exclude any liability for fraud or fraudulent misrepresentation;
(c) limit any liabilities in any way that is not permitted under applicable law; or
(d) exclude any liabilities that may not be excluded under applicable law.
6.2 The limitations and exclusions of liability set out in this Section 6 and elsewhere in these terms and conditions:
(a) are subject to Section 6.1; and
(b) govern all liabilities arising under these terms and conditions or relating to the subject matter of these terms and conditions, including liabilities arising in contract, in tort (including negligence) and for breach of statutory duty, except to the extent expressly provided otherwise in these terms and conditions.
6.3 To the extent that our website and the information and services on our website are provided free of charge, we will not be liable for any loss or damage of any nature.
6.4 We will not be liable to you in respect of any losses arising out of any event or events beyond our reasonable control.
6.5 We will not be liable to you in respect of any business losses, including (without limitation) loss of or damage to profits, income, revenue, use, production, anticipated savings, business, contracts, commercial opportunities or goodwill.
6.6 We will not be liable to you in respect of any loss or corruption of any data, database or software.
6.7 We will not be liable to you in respect of any special, indirect or consequential loss or damage.
6.8 You accept that we have an interest in limiting the personal liability of our officers and employees and, having regard to that interest, you acknowledge that we are a limited liability entity; you agree that you will not bring any claim personally against our officers or employees in respect of any losses you suffer in connection with the website or these terms and conditions (this will not, of course, limit or exclude the liability of the limited liability entity itself for the acts and omissions of our officers and employees).
7. Breaches of these terms and conditions
7.1 Without prejudice to our other rights under these terms and conditions, if you breach these terms and conditions in any way, or if we reasonably suspect that you have breached these terms and conditions in any way, we may:
(a) send you one or more formal warnings;
(b) temporarily suspend your access to our website;
(c) permanently prohibit you from accessing our website;
(d) block computers using your IP address from accessing our website;
(e) contact any or all of your internet service providers and request that they block your access to our website; and/or
(f) commence legal action against you, whether for breach of contract or otherwise.
7.2 Where we suspend or prohibit or block your access to our website or a part of our website, you must not take any action to circumvent such suspension or prohibition or blocking.
8.1 We may revise these terms and conditions from time to time.
9.1 You hereby agree that we may assign, transfer, sub-contract or otherwise deal with our rights and/or obligations under these terms and conditions.
9.2 You may not without our prior written consent assign, transfer, sub-contract or otherwise deal with any of your rights and/or obligations under these terms and conditions.
10.1 If a provision of these terms and conditions is determined by any court or other competent authority to be unlawful and/or unenforceable, the other provisions will continue in effect.
10.2 If any unlawful and/or unenforceable provision of these terms and conditions would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect.
11. Third party rights
11.1 A contract under these terms and conditions is for our benefit and your benefit, and is not intended to benefit or be enforceable by any third party.
11.2 The exercise of the parties' rights under a contract under these terms and conditions is not subject to the consent of any third party.
12. Entire agreement
12.1 Subject to Section 6.1, these terms and conditions, together with our privacy and cookies policy, shall constitute the entire agreement between you and us in relation to your use of our website and shall supersede all previous agreements between you and us in relation to your use of our website.
13. Law and jurisdiction
13.1 These terms and conditions shall be governed by and construed in accordance with English law.
13.2 Any disputes relating to these terms and conditions shall be subject to the exclusive jurisdiction of the courts of England.
14. Our details
14.1 This website is owned and operated by Mvine Limited.
14.2 We are registered in England and Wales under registration number 05313963, and our registered office is at Downsview House, 141-143 Station Road East, Oxted, Surrey, RH8 0QE.
14.3 Our principal place of business is at Downsview House, 141-143 Station Road East, Oxted, Surrey, RH8 0QE.
14.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using the email address published on our website.
General Data Protection Regulation (GDPR)
Confidentiality, integrity and availability are where Mvine start, not finish. Data protection is serious and GDPR should be read alongside Data Protection Act 2018 (DPA 2018).
The key design principle of Mvine’s One Cyber-Secure Platform is zero trust, making it impossible for anyone to access any information about anything held in the system unless they have been duly identified, authenticated and authorised. In other words, our privacy by design defaults to no access unless it is expressly given rather than full access unless it is removed. It's all about preventing the misuse of personally identifiable information.
This means the platform we deliver to you helps you take account of GDPR and helps you to assure compliance.
GDPR introduced on 25th May 2018 requires that you have taken account of:
The seven key principles
The lawful basis for processing
The eight Individual rights
Accountability and governance
Personal data breaches
For more information about GDPR, please visit the ICO website.