Privacy Policy

Privacy policy

Our website respects your privacy and seeks to protect your personal information.
The privacy policy explains how we collect and use your personal data (under certain circumstances). Do not forget the procedures used to ensure the confidentiality of your information. Finally, this policy determines your options regarding the collection, use and disclosure of personal data. By visiting the site directly or through another website, you agree to the practices described in this policy.
The protection of your data is very important to us. Therefore, your name and other information about you are used in accordance with the terms stated in the privacy policy. We will collect information if necessary or if it is directly related to our relationship with you.
We will keep your data in accordance with the law or use it for the purposes for which it was collected.
You can browse the site without having to provide personal data. Your personal identity remains anonymous throughout your visit to the site and is not exposed unless you have a special online account on the site you are accessing with a username and password.
1- The data we collect :
We may collect your information if you wish to order an item on our site.
We collect, store and process your data necessary to continue your purchase on our site in order to secure any requests that may arise later, and to provide you with the services available to us. We may collect personal information including, but not limited to, name, gender, date of birth, email address, postal address, delivery address (if different), phone number, payment details, and payment card details.
We use the information you provide to enable us to process your requests and to provide you with the services and information displayed on our site that you request. In addition, we will use the information you provide to manage your account with us, to verify your financial transactions on the Internet, to audit the download of data from the site, identify site visitors, develop designs and / or content for site pages and assign them to users. We do a lot of research related to demographics and send useful or required information to the user, for example information about products and services, in case you do not object to contact you about it. We communicate by e-mail to provide details of other products and services if you wish, and if you prefer to receive no promotional and marketing communications, please remove yourself from this option at any time.
We may give your name and address to a third party to give you your purchase order (for example, delivery agent or supplier).
We may be able to store details about your current order on our site, but we can not recover it directly for security reasons. By logging into your account on the site, you can view information and details of your purchases that you have requested or that you submit soon. You can also manage your address details. You must also agree to respect full confidentiality when accessing your personal data, so do not put them at the disposal of an unauthorized third party. We assume no liability for the misuse of passwords unless this misuse is caused by an error on our part.
Other uses of your personal information
We may use your personal information in opinion polls and marketing surveys, at your discretion, for statistical purposes while ensuring their complete confidentiality, and you have the right to remove them at any time. We do not send any response to third parties. Your e-mail address is only disclosed if you wish to enter the contest. We keep survey responses completely separate from your private email.
We may send information about us, or the site or our other sites, or our products, sales, offers, sales, newsletters, and other things related to affiliates of our group or our partners. If you do not wish to obtain this additional information (or part of it), please click on the "unsubscribe" link in any email that will be sent to you, and we will stop sending you this information within seven days working days (every day except Saturdays, Sundays and national and religious holidays) to receive your notification. We will contact you to inquire about the information when it is not clear.
We may use certain data, while preserving site privacy and confidentiality, for other purposes, including to check where users are and after their visit to the site or links in email while they subscribe to receive it, and to provide this anonymous data, which does not allow the identification of your personal identity. Real, to a third party, for example, from publishers. However, this data will not identify you (as it is not personally identifiable).
Competitions
In the context of any competition, we use the data to inform the winners and announce our offers. You can find more details on the conditions of participation in each competition separately.
Third parties and links to websites
We may transfer your information to other companies in our group or to our agents and subcontractors to assist us in related transactions in accordance with the terms of this privacy policy. For example, we may turn to a third party to help deliver products, receive payments from you, and use them for statistical or marketing research purposes or to assist our customer service team. We may need to exchange information with a third party to protect against fraud and reduce credit risk. In the event that our company or part of it is sold, we may have to transfer our databases which contain your personal information. Except as set forth in this Privacy Policy, we will not sell or disclose your personal information to any third party without your prior approval, except as may be necessary for the purposes set forth in this Privacy Policy, or if we are required to do so by law. The site may contain third party advertisements or links to other websites or frames from other sites. We inform you that we are not responsible for the privacy policy of a third party or the content of these policies applied in other sites, and we are not responsible for third parties to whom we transfer your data in accordance with the policy of confidentiality.
2 - COOKIES
Accepting cookies is not a prerequisite for visiting the site. However, we note that the "basket" functions of the site can not be used and requested for any purpose whatsoever without the activation of cookies. Cookies are small text files that allow our server to identify your computer as a single user when visiting certain pages of the site. Your browser stores these files on your computer's hard drive. Cookies can be used to discover an Internet Protocol (IP) address, saving you time when you are on the site or want to visit it. We use cookies to ensure your comfort while browsing this site (for example, remember your identity when you want to change your cart without having to re-enter your email address) and not to obtain or use other information about you (for example for targeted marketing purposes). You can set your browser to not accept cookies, but this will limit your use of the site. We hope that you make sure that our use of cookies does not contain any personal or private information and is free of viruses. This website uses Google Analytics, a service provided by Google to analyze web pages. To analyze how users use the site, Google Analytics is based on cookies, which are text files placed on your computer. Google will transfer the information generated by the cookie about your use of this website (including your IP address) to servers in the United States where it will be stored. Google will use this information to evaluate your use of the site, prepare reports for website operators about its activity, and provide other services related to website activity and internet usage. Google may also transfer this information to a third party if required by law or if a third party processes the information on behalf of Google. Google will not associate your IP address with other data that it retains. You can refuse to use cookies by selecting the appropriate settings on your browser, but remember that you will not be able to enjoy all the features of the site. By using this site, you agree that Google uses your data as described and for the purposes described above.
3- Security
We use appropriate security techniques and procedures to prevent unauthorized or unlawful access to your information or loss or destruction. When we collect data via the website, we store your personal information in a database on a secure online server. We use firewall systems on our servers. When we collect payment card information electronically, we protect it by using encryption, such as Secure Sockets Layer (SSL). It is therefore difficult for any hacker to decrypt your information, because we can not guarantee a 100% protection. We strongly advise against sending all credit or debit card details when communicating with us electronically and without encryption. We put in place direct physical, electronic and procedural guarantees on the process of collection, storage and disclosure of your information. Our security procedures require that we sometimes ask you to verify your identity before disclosing your personal information. It is your responsibility to protect your password and computer against unauthorized use.
4 - Customer rights
In the event that you are concerned about your data, you have the right to request access to personal data that we hold about you or that we have previously been given. You have the right to ask us to correct any errors in your personal data, and this is done free of charge. You also have the right to ask us, at any time, to stop using your personal data for direct marketing purposes.
Privacy Policy Effective date: 31 January 2020 This is the privacy policy ("Privacy Policy") for information collected by milajoy. Management Company, https://www.milajoy.com Management Company Limited (together “milajoy.com ”) and for https://www.milajoy.com/ ("Site"). The Site is operated by or on behalf of https://www.milajoy.com Our Privacy Policy explains: ●
What information we collect and why we collect it. ●
How we use that information. ●
The choices we offer, including how to access and update information. We’ve tried to keep this Privacy Policy as simple as possible but if you have any questions, please feel free to contact us at [email protected]. Information that we collect We collect information to provide better services to all those with whom we deal. We collect information in the following ways: ●
Information you give us. For example, information that you provide to us when contacting us for inquiries about potential investment or other commercial opportunities, employment details if you send us a CV, resumé or other details of your employment history in connection with an advertised job vacancy or a general enquiry regarding employment opportunities with us. When you do, we may ask for personal information like your name, email address, telephone number and other details. ●
Information we collect or receive in the course of our investment business. We may receive or collect personal information in the course of our investment activities, such as when researching potential investment opportunities or in conducting our legal and commercial due diligence. This could include, for example, information about the management and other personnel at a company we may be assessing an investment in. ●
Information we get from your use of our Site. We may collect information about the parts of the Site that you use and how you use it. This information includes: ○ Device information We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). ○ Log information When you use our Site, we may automatically collect and store certain information in server logs. This may include: ●
details of how you used our Site; ●
Internet protocol address; ●
device event information, such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL; and/or ●
cookies that may uniquely identify your browser. ○ Location information We may collect and process information about your actual location and use various technologies to determine location, including IP address. ○ Local storage We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches. ○ Cookies and similar technologies We may use various technologies to collect and store information when you visit our Site, and this may include using cookies or similar technologies to identify your browser or device. You may set your browser to block all cookies, including cookies associated with this Site or to indicate when a cookie is being set by us. How we use information that we collect We use personal information to manage and operate our business, including to explore new investment opportunities, manage our existing portfolio, develop and maintain our contacts and recruit staff. Where necessary, we may also use personal information to protect the interests of milajoy, our employees and affiliates (for example in the event of a legal claim). When you contact us, we keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our business, such as letting you know about upcoming events or changes to our business. We use the information we collect from our Site to provide, maintain, protect and improve it and to protect our users. We may use information collected from cookies and other technologies to improve your user experience and the overall quality of our Site. Our legal basis for processing your personal information If EU data protection law applies to our processing of your personal information, it is important that you know the lawful basis on which we process your personal information. We rely on the following legal basis, under EU data protection law, to process your personal data:
Where we have obtained your consent, for example to action a request from you or respond to your specific query. You can withdraw your consent at any time, but we may still need to retain a record of your correspondence with us. ●
Where it is necessary for the purposes of our legitimate interests to manage our existing investments and explore new investment opportunities, including conducting legal and commercial due diligence. ●
Where it is necessary to comply with a legal obligation, for example under anti-money laundering or anti-bribery legislation. Transfer of personal information milajoy is headquartered in the US, with an office in the UK. Consequently, any information we collect will be transferred to, and stored in, the US and other countries where the data protection laws may offer a lower standard of protection than in your country of residence. Where personal information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards and that it is treated securely and in accordance with this Privacy Policy. Adhesion to the Privacy Shield FrameworksManagement Company, L.L.C. has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. We comply with the EU-U.S and Swiss-US Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, United Kingdom and Switzerland to the United States, respectively. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Framework, and to view our certification, please visit https://www.privacy milajoy.com/. Accountability for onward transfers We are responsible and remain liable for the processing of personal information we receive, under the Privacy Shield Frameworks, including if we subsequently transfer to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions. With respect to personal information received or transferred pursuant to the Privacy Shield Frameworks, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Resolution of Privacy Shield queries and complaint mechanism In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. European Economic Area and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at [email protected]. We have further committed to refer unresolved Privacy Shield complaints to JAMS. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit https://www.milajoy.com/eu-us-privacy-shield or to file a complaint visit https://www.milajoy.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim. The services of JAMS are provided at no cost to you. As further explained in the Privacy Shield Principles, a binding arbitration option may also be made available to you in order to address residual complaints not resolved by any other means. We commit to cooperate with the EU DPA panel established by the EU data protection authorities ("EU DPA panel") and the Swiss Federal Data Protection and Information Commissioner (as applicable) and to comply with the advice given such EU DPA panel and/or the Swiss Commissioner (as applicable) with regard to human resources data transferred from the EU DPA and/or Switzerland to milajoy.com Management Company, L.L.C. in the context of the employment relationship. Enforcement milajoy.com is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. milajoy.com may be required to share your personal information, including the disclosure of EU and Swiss personal information, to public authorities and law enforcement agencies in response to lawful requests, including requests to meet national security and law enforcement requirements. Right to access, update and delete your personal information If you are a resident of California or the European Economic Area (EEA) and/or your personal information is processed in the context of our UK office, you have certain legal rights in respect of the personal information about you held by us, including, for California residents, your rights under the California Consumer Privacy Act (CCPA). This includes the right to obtain a copy of this information on request, and the right to correct, amend or delete such personal information or object to it being used for certain purposes (including marketing). We may ask you to verify your identity before we can act on your request. We will comply with any requests to exercise your rights in accordance with applicable law, and so there may be circumstances where we are entitled to refuse your request. For example, where permitted to by law, we may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems). Where we can provide information access and correction, we will do so free of charge, except where it would require a disproportionate effort (where we are permitted to charge a fee under applicable law). We aim to maintain any information we hold and our Site in a manner that protects information from accidental or malicious destruction. To make any requests regarding your personal information, or if you have any questions or concerns regarding your personal information, you should contact us at [email protected]. You are also entitled to contact your local supervisory authority for data protection. In the UK, the data protection authority is the Information Commissioner’s Office. Right to object You have the right to object (opt-out) of your personal information being used for purposes which are materially different to the purposes for which it was collected, as described in this Privacy Policy (including being disclosed to a third party). We may refuse your request where we have a right to do so (for example, if the use is necessary to comply with a legal obligation). To exercise any of your rights, please contact us [email protected] Information that we share We do not sell your personal information. We share personal information with companies, organisations and individuals outside ofmilajoy.com in the following circumstances: ●
With your consent We may share personal information with companies, organisations or individuals outside milajoy.com when we have your consent to do so. ●
For external processing We provide personal information to our affiliates or other trusted businesses or persons to process it for us or for similar reasons (for example, in connection with using shared compute resources and servers), based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. ●
With our legal and professional advisors We share information with our legal and other professional advisors, for example if they are advising us on an investment transaction or where otherwise necessary to obtain their advice. ●
For legal reasons We may share personal information with companies, organisations or individuals outside milajoy.com if we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to: ● meet any applicable law, regulation, legal process or enforceable governmental request; ●
enforce applicable terms of service, including investigation of potential violations; ● detect, prevent or otherwise address fraud, security or technical issues; and/or ●
protect against harm to the rights, property or safety of GV, our users or the public, as required or permitted by law. If milajoy is involved in a merger, acquisition or asset sale ofmilajoy, we will use reasonable endeavours to ensure the personal information we process continues to be subject to the same protections set out in this Privacy Policy. Information security We work hard to protect our Site and any information that we hold from unauthorized access or unauthorized alteration, disclosure or destruction. In particular: ●
We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. ●
We restrict access to personal information to milajoy employees, contractors, service providers and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated if they fail to meet these obligations. THANK YOU