Privacy Policy

1. Introduction

Mångata is made up of (a) Mångata Networks LLC a company incorporated under the laws of the State of Delaware, with a principal place of business at 8736 East Quartz Mountain Drive, Gold Canyon, AZ 85118, United States of America and (b) Mångata Networks Limited, a company incorporated in England, with its registered office at Ibex House 162-164 Arthur Road, Wimbledon, London, United Kingdom, SW19 8AQ. This privacy policy is issued on behalf of both Mångata Netwoks LLC and Mångata Networks Limited so when we mention “Mångata”, "we", "us" or "our" in this privacy policy, we are referring to the relevant company responsible for processing your personal information. Mångata Networks LLC is the controller and responsible for this website.

We have appointed [insert name] as the person with responsibility for our data protection compliance. If you have any questions about this privacy policy, including any requests to exercise your legal rights in relation to your personal information, please contact [insert name] using the details set out below:

[Insert contact details for the data protection officer]

We are the data controller of the personal information that we keep and use. We are responsible for ensuring that all of our procedures and those who use them are compliant with the relevant data protection laws in respect of that personal information.

We are committed to safeguarding the privacy of information provided to us in course of our business and information we receive through our website. This Privacy Policy sets out the ways in which we collect and use your personal information. It also explains what rights you have to access or change your personal information.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information.

2. Changes to the privacy policy and your duty to inform us of changes

We may update this privacy policy from time to time and will make updates available on our website. This privacy policy was last updated on [insert date].

It is important that the personal information we hold about you is accurate and current. Please notify us at using the contact details set out above of any changes to your personal information.

3. Sources of personal information

We collect personal information about you from different sources, including:

  • Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:

  • apply for our products or services;

  • providing us with a business card

  • create an account on our website;

  • subscribe to our service or publications;

  • request marketing to be sent to you;

  • enter a competition, promotion or survey; or

  • give us some feedback.

  • Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

  • Third parties or publicly available sources: We may receive personal information about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:

    • (a) analytics providers such as Google based outside the EU;

    • (b) advertising networks based inside OR outside the EU; and

    • (c) search information providers inside OR outside the EU.

  • Contact, and Transaction Data from providers of technical, payment and delivery services inside OR outside the EU.
     

[We have listed above the typical sources from which we might expect Mångata to receive personal information, please review the list and let us know of any additions or deletions.]

4. The personal information we collect

Personal information, or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect the following types of personal information about you:

  • Identity Data includes [full name, username or similar identifier, marital status, title, date of birth and gender];

  • Contact Data includes [billing address, delivery address, email address and telephone numbers];

  • Financial Data includes [bank account and payment card details];

  • Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us];

  • Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website];

  • Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses];

  • Usage Data includes [information about how you use our website, products and services]; and

  • Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
     

[We have listed the typical types of personal information we might expect Mångata to collect, please review the list and let us know of any additions or deletions.]

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your personal information but is not considered personal information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

5. Using your personal information

We only ever use your personal information if and to the extent that applicable law allows.

Therefore, we will only process your personal information if:

  • it is necessary for the performance of a contract with you or the organisation you work for;

  • it is necessary in connection with a legal obligation;

  • you have given your consent (where necessary) to such use or the organisation you work for has obtained your consent (where necessary) to share your personal information with us; or

  • if we (or a third party) have a legitimate interest which is not overridden by your interests or your rights and freedoms. Such legitimate interests include the provision of our services, running our business and marketing relevant services directly to you.

Please note, therefore, that we may use your personal information in order to:

  • comply with our legal obligations;

  • deliver services to you and/or the organisation for whom you work;

  • run our business;

  • improve the services and products that we offer to you or the organisation for whom you work;

  • send you marketing materials and invite you to events (where consent has been given); or

  • process and respond to requests, enquiries or complaints received from you.

[We have listed the typical purposes for which we might expect Mångata to process personal information, please review the list and let us know of any additions or deletions.]

6. Keeping your personal information

We will only ever keep personal information about you for as long as is necessary to address the purpose for which it was collected. This includes complying with any legal, regulatory, accounting or reporting requirements. In relation to the provision of services to you this will be in accordance with our retention and destruction policy unless we agree otherwise with you, in writing. To find out more about our retention and destruction policy please contact us.

[Reference is made here to a retention and destruction policy. Mångata should have a retention and destruction policy in place in respect of any personal data records that it keeps.]

7. Sharing personal information

There are times when we may need to share your personal information with third parties. Those third parties may include:

  • to other members of the Mångata group of companies, who will also act as joint controllers of the personal information;

  • regulators, government agencies, courts and other similar regulatory and official third parties, including where we are under a legal duty to do so;

  • our professional advisers and auditors and those who provide services on our behalf and may need access to your information – for example an IT supplier may have access to your personal information when providing IT support or hosted cloud services or a mailing company may process the personal information of our contacts for us; and

  • third parties to whom we may sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy policy.

Please note that we will never send marketing communications via SMS or call you without your specific consent and we will not pass on or sell your personal information to a third party.

[We have listed the typical types of third parties to whom we might expect Mångata to transfer personal information, please review the list and let us know of any additions or deletions. If there are specific third parties to whom you will transfer personal information these should be added.]

8. Transferring your personal information internationally

Mångata Networks LLC is located in the United States of America. If you live in a country with strict data privacy laws such as Canada, any constituent part of the European Union, Israel, Japan, New Zealand, Switzerland or the United Kingdom you should be aware that any personal information that you provide to us will be transferred to countries with less strict data privacy laws.

Any personal information that you provide to Mångata Networks Limited will be shared with Mångata Networks LLC and may be transferred to a country with less strict data privacy laws. Any personal information shared by Mångata Networks Limited with Mångata Networks LLC will be shared in a manner that complies with applicable law, such as a model contract.

[We assume that the English company is essentially dormant at the moment. If and when it starts collecting personal data and sharing that personal data with the US company, you will need to put in place a legal method of transferring that personal data outside of the UK, such as a model contract.]

 

9. Keeping your personal information secure

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected breach of personal information and will notify you and any applicable regulator of a breach where we are legally required to do so.

Please always be aware, however, that information sent over the internet is rarely completely secure and whilst we will always take the most appropriate steps to protect your persaonl information, we cannot guarantee the security of any information transmitted electronically and accept no responsibility for any damage or loss caused.

10. Your rights

You may have the following rights in relation to the personal information that we hold about you:

  • the right to request rectification of personal information that is inaccurate or incomplete;

  • the right to erasure of your personal information (sometimes referred to as the “right to be forgotten”);

  • the right to object to, or restrict, the way in which we are dealing with and using your personal information; and

  • the right to request that your personal information be provided to you in a format that is secure and suitable for re-use (known as the “right to portability”).
     

Please note, however, that there may be limitations placed upon this by circumstances, such as when we need to retain personal information for legal purposes or to perform our services for you.

You have the right to make what is known as a Subject Access Request to find out details of the personal information that we hold about you, and the uses to which it is put. Such requests can be made in any form, but it is easier and safer if they are made to us in writing.

Subject to the performance of our contractual services to you, you have the right to withdraw consent that you may have provided to the collection, processing and transfer of your personal information for a specific purpose at any time. Once we have received notification that you have withdrawn your consent, we will no longer process that personal information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not, in general, have to pay a fee to exercise any of your individual rights set out in this privacy policy unless the use you make of this provision becomes excessive and we are entitled in law to make such a charge.

11. Third Party Links

Our website may contain links that will direct you to other websites or services that are operated and controlled by third parties. We have no control over these third parties, and your use of their websites and features are subject to their privacy policies. We cannot be held responsible for the privacy practices or business practices of any third-party website.

12. Cookies
 

Our website uses cookies. These are small files created and stored on your browser or the hard drive of your computer by websites that you visit to help the website operate properly, grant appropriate access to previous users and to monitor website traffic. Cookies are generally only visible to the website that serves them and not to other websites.

Cookies are used on our website to ‘remember’ information so that it can be passed from page to page and to collect website statistics. This data collected can help to improve our website and the services that we offer.

You can, if you wish, delete or disable cookies within your browser. The process will usually be explained in your internet browser’s ‘Help’ menu. Please be aware, however, that if you disable cookies then, whilst you may be able to browse all of our website, some of the cookies we use may be essential for the website to operate and some features may, therefore, not be available to you. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies as soon as you visit our website.

 
 
 
 
 
 
 
 
 
 
 
 
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Mangata Networks  © 2020

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