Privacy

MVN Asset Management Limited

MVN Asset Management Limited Privacy Statement

We respect the privacy of every person who visits or registers with the MVN Asset Management Limited Client Portal (the “Site”) and uses the services made available by us from or through the Site (the “Service”) and we are committed to ensuring a safe online experience.

Purpose of this notice

This privacy notice explains our approach to any personal information that you might supply to us either directly (or that might be collected from you) or in connection with your use of the Client Portal and/or interest in the potential provision of asset management services and sets out your rights in respect of our processing of your personal information.

This privacy notice will inform you how you can verify which of your personal information is collected by us through and registered on the MVN Asset Management Client Portal and how you can request that we delete, update or transfer it.

This privacy notice is intended to assist you in making informed decisions when using the Service. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Website Terms of Use .

Please also note that this privacy notice only applies to the use of personal information collected by us from your use of the Service or during your communications with us. It does not apply to personal information collected during your communications with third parties.

Who are we and what do we do?

The Service is operated by MVN Asset Management Limited (“we” “us” or “our”) whose principal activities include asset management and related investor management services.

MVN Asset Management Limited is the data controller responsible for your personal information.

MVN Asset Management Limited is an English company with registered company number: 09659116 and whose principal address is Level 5 – 140 Leadenhall Street, EC3V 4QT, England.

1. How to contact us?

If you have any questions about this privacy notice or want to exercise your rights, please contact us by:

sending an e-mail to dataprivacy@mavensecurities.com and IR@mvnassetmanagement.com; or
writing to us at “Data Privacy – Level 5 – 140 Leadenhall Street, EC3V 4QT, England.

2. What personal information do we collect and how do we collect it?

Personal information may be collected from you in the following ways:

  • Information you voluntarily provide to us.

We collect and maintain personal information that you voluntarily submit to us during your use of the Service (e.g. when registering with us, during the course of e-mail exchanges with us or when we exchange contact details at investor (or other) events).

In particular, in order to sign up and create an account we request the following personal information from you:

name;
company name;
title;
investor categorisation
office location;
e-mail address;
phone number.

Other than the information which is definitely required to set up your account you have the flexibility to provide us with as little or as much of this requested information as you like. However, the more information you provide, the more you will get out of the Service. 

If you contact us, we may collect additional personal information from you such as your opinion on our service.

  • Information we collect through your use of the Service.

Through our use of log files and other technologies, we may collect personal information regarding your mobile device or the computer hardware and software used to access the Service. This may include the following:

Name or user account details; and
access times and dates.

We also collect personal information regarding your use of and activity on the Service.

  • Information we collect from third parties.

We may also combine personal information that we collect through your use of the Service with personal information that: a) you have provided to third parties and in respect of which you have given the third- party permission to share with us; and/or b) we have obtained from a public record. For example, if you (i) agree to share information with us through capital introduction events hosted or facilitated by third party service providers or (ii) choose to provide your payment/ID information to our fund administrator to subscribe into one of our managed funds, we are provided with such information to facilitate ID checks and transfers to and from the fund accounts.

3. How do we use your personal information?

Potential uses of your personal information allows us to:  

verify your identity and perform KYC checks,

provide investor management services and update you on the performance of our Service,

carry out transaction, activity or request made by you in connection with the Service,

investigate or settle inquiries or disputes,

comply with any applicable law, court order, other judicial process, or the requirements of a regulator or tax authorities,

enforce our agreements with you,

protect the rights, property or safety of us or third parties, including other users of the Site,

provide support and security for the Services,

use as otherwise required or permitted by law, and

aggregate and anonymise this information in order to provide sector or jurisdiction-specific reports to senior management and business partners. In particular, we may use your personal information for the following purposes:

  • Provision of the Service.

We use this information to communicate with you and to carry out actions you request on the Site, such as requests for documentation, periodic performance updates and to provide marketing materials and newsletters and to provide fund administration services.

What is our legal basis?

It is necessary for us to use your personal information to provide the Service to you and perform our obligations in accordance with any contract that we may have with you (e.g. processing your bank account details in order to facilitate your subscription into the Fund after you execute a Subscription Agreement).

It is also in our legitimate interest to use your personal information in such a way to ensure that we provide the very best investor management services we can to you. We also need your personal data to verify your ID, and perform certain background checks in compliance with applicable laws (including but not limited to anti-money laundering, terrorism)

  • Information Requests and Feedback.

Our Service contains various user interfaces to allow visitors to request more information about our products and services, to use the functionalities of the site, or to provide us with feedback about them. Contact information may be requested in each case, along with information about your computing environment and/or industry, and details of your request or reported feedback. This information is used in order to allow us to respond to your requests, to assure that our software and services work correctly.

What is our legal basis?

It is in our legitimate business interests to respond to any requests you make to us or use the information you provide to us in your feedback in order to improve our products and services.

  • Profiling.

We may use your information for customer profiling to ensure that we market the most suitable products and services to you.

What is our legal basis?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you. 

  • Service administration.

We may use your personal information to:

develop and improve the Service;
send you administrative e-mails about the Service; and
contact you to answer any queries you may have.

What is our legal basis?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.

  • User Data Analysis.

Our Site keeps a record of individual user accounts that access and download materials from our Site. By using this information, we are able to measure the effectiveness of our content, ensure access controls and how visitors use our Site.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. However where your personal information is not in an anonymous form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market and to check our materials are being accessed.

  • Internal record keeping and legal compliance.

We may use your personal information for internal record keeping purposes and to check you comply with the Website Terms of Use.

What is our legal basis?

It is in our legitimate interest to ensure that we keep our records up-to-date in order to monitor who uses the Service, to comply with our legal, regulatory obligations and to monitor your compliance with the relevant Terms of Use.

  • Marketing by us.

Submission of your email address on the Site will result in your being added to our mailing list for purposes of product updates, promotional and marketing messages, monthly newsletters and other communications, until such time as you opt out.

What is our legal basis?

It is in our legitimate interests to market our products and services.

  • Using CCTV

We may use CCTV provided by building management in rare circumstances for access control security and crime prevention.

What is our legal basis?

It is in our legitimate interests to protect our business from theft and so ensure proper access controls are in place and we only access the building’s CCTV footage in accordance with our data retention police or where required by law.

  • Sharing information with third parties.

We will share your personal and corporate information with our subsidiaries, affiliates and other related companies and branches for purposes that are consistent with this privacy policy. Data collected online about you or your company may also be combined with information that you provide when you register to use any of the Sites.

We may share your personal information collected on the Site with third parties as necessary or appropriate to:

(i) carry out the transaction, activity or request made by you on the Site,
(ii) comply with any applicable law, court order, other judicial process, or the requirements of a regulator or tax authority,
(iii) enforce our agreements with you,
(iv) protect the rights, property or safety of us or third parties, including other users of the Sites,
(v) perform investigative security analysis on the Site, or
(vi) as otherwise required or permitted by law.

What is our legal basis?

It is in our legitimate interest to share your personal information in such a way to ensure that we provide the very best service we can to you. Where we share your sensitive personal information, we shall be relying on your consent to do so.

  • Sharing information with professional advisors & regulatory authorities and potential purchasers.

We may share your personal information with professional advisers or regulatory authorities:

(i) to enable them to process your personal information on our behalf in a manner consistent with this privacy notice;
(ii) to comply with our legal obligations;
(iii) to enforce our legal rights; or
(iv) protect rights of third parties.

Your personal information may also be shared with prospective buyers in the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

What is our legal basis?

It is in our legitimate interest to share your personal information with such third parties to enable them to process your information on our behalf, to comply with and/or enforce our legal rights and obligations, to protect the rights of third parties and to facilitate business transitions.

Any other purposes for which we wish to use your personal information will be notified to you either by updating our privacy notice or otherwise from time to time including the legal basis of such use.

4. How do we obtain your consent?

Where our use of your personal information requires your consent, you can provide such consent:

at the time we collect your personal information following the instructions provided; or
by informing us by e-mail, post or phone using the contact details set out above in this privacy notice.

5. Transfers outside the EEA

As part of a global network of group companies, we transfer your personal data outside the EEA to our group members and third parties where strictly necessary to carry out our business services subject to adequate safeguards. We will ensure that the transfer is lawful and that there are appropriate security arrangements.

Where we do transfer data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be subject to adequate protections under applicable data protection legislation, such as the EU approved model clauses, which you can find by clicking here.

6. How long do we keep your personal information for?

We do not keep your personal information for any specific period but we will not keep it for longer than is necessary for our purposes.

In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations. Absent of any specific business, legal or regulatory requirements, our standard retention period for records and other documents is 7 years

If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it.

7. Confidentiality and security of your personal information

We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. 

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

unauthorised access;
improper use or disclosure;
unauthorised modification; and
unlawful destruction or accidental loss.

All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Service.

8. How to access your information and your other rights?

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

  • Your right of access.

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

  • Your right to rectification.

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

  • Your right to erasure.

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

  • Your right to restrict processing.

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

  • Your right to data portability.

With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.

  • Your right to object.

You can ask us to stop processing your personal information, and we will do so, if we’re:

relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
processing your personal information for direct marketing; or
processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.

  • Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

  • Your right to withdraw consent.

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

  • Your right to lodge a complaint with the supervisory authority.

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

9. Change to this privacy notice

We may make changes to this privacy notice from time to time.

To ensure that you are always aware of how we use your personal information we will update this privacy notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by e-mail of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of how we use your personal information.

Last Updated 25 May 2018