WHAT TYPES OF INFORMATION MAY WE COLLECT THROUGH OUR SITE?
- We may collect information from or about Site users concerning use of the Site.
- We may collect Personal Data that you provide directly to us if and when you enter certain information on our Site. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, location, e-mail address, as well as any other non-public information about you that is associated with or linked to any of your data.
- We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to us and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at firstname.lastname@example.org.
MPM is headquartered in the United States, and your Personal Data may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your Personal Data may not be as protective as the privacy laws in your home country.
HOW AND WHY DOES MPM USE THIS PERSONAL INFORMATION?
MPM collects and processes your personal information:
- Where required by applicable laws and regulations, including, but not limited to, laws relating to know-your-client requirements, tax, the prevention of money laundering, fraud, terrorist financing and sanctions, which may involve collecting specific personal information about you as required by law and disclosing such information to applicable regulators, government bodies, and tax authorities;
- Where the processing is necessary for MPM to enter into or to perform a contract with you, or to take steps at your request prior to entering into a contract; for example, to process your subscription agreement, provide information you have requested, create and administer your account, administer your investments, maintain registers, and communicate with you about your investments;
- Where necessary for the purposes of MPM’s legitimate interests or with your consent, including, but not limited to, operating and facilitating our business and services to you, undertaking business management, planning, statistical analysis, market research and marketing activities, administering and maintaining MPM’s core records, protecting MPM’s rights and interests, ensuring the security of MPM’s assets, systems, and networks, preventing, detecting, and investigating fraud, unlawful, or criminal activities in relation to our services, and enforcing our terms and conditions; and
- Where the processing is necessary for the establishment, exercise, or defense of legal claims.
MPM may process your personal information on the basis of our legitimate commercial interests, where the processing is necessary for the performance of a contract with you or to protect your vital interest, or where we have received your consent. Where processing is based on your consent, you have the right to withdraw that consent at any time. If you decline to provide or withdraw your consent to our use of the data and we are relying on consent as the legal basis for its processing, there are circumstances in which we will not be able to provide you with services or take action on your behalf. Where we process your personal information on the basis of our legitimate interests, we may do so for our, or our affiliate’s, everyday business purposes, such as to process your transactions, maintain your account(s), or respond to court orders and legal investigations. MPM may also process your data to offer products or services to you.
In addition, we may share non-personally identifiable Site usage information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information. The third parties that support our website analytics tools may be able to access and use your Site usage information.
WHEN DO THIRD-PARTY PRIVACY POLICIES COME INTO PLAY?
We maintain presence on several social media platforms, and we may also incorporate some third-party social media features onto the Site. We may also include tools on the Site that allow you to share and/or publicly post content or information from the Site to your profile on a third-party social media platform. Third-party social media platforms have their own privacy policies which explain how they will use, protect and share your information, including any information you share on those platforms from the Site, and we encourage you to read them.
Information that you may provide, or that we may obtain, through your access to password-protected websites, such as an investor portal, that you may be able to access by following a hyperlink on the Site (each such other website, an “Access-Restricted Website”), is subject to the privacy policies and practices of the operators of the Access-Restricted Website available on such Access-Restricted Website, which we encourage you to read to learn about the treatment of such information.
DATA SECURITY AND DISCLOSURES OF YOUR PERSONAL INFORMATION
MPM is committed to maintaining the confidentiality, integrity, and security of your personal information and takes precautions to protect such personal information. These precautions include the adoption of certain physical, electronic, and procedural safeguards and procedures designed to maintain and secure your personal information from inappropriate disclosure, in accordance with applicable laws and regulations, while allowing your needs to be met.
MPM restricts access to personal information about investors and clients to those employees and agents of MPM who need to know that personal information in order to provide MPM’s services to investors and clients. MPM may disclose such personal information to its third-party service providers (including, but not limited to, financial, technical, legal, marketing, and professional service providers and consultants) and financial institutions that provide services to MPM. MPM requires such third-party service providers and financial institutions to protect the confidentiality of your personal information and to use the personal information only for purposes for which it is disclosed to them.
MPM may also disclose your personal information to other third parties, including, but not limited to:
- any governmental agency, regulatory authority, or self-regulatory organization having jurisdiction over MPM or its affiliates, if (1) MPM determines that such disclosure is necessary or advisable pursuant to, or in connection with, any U.S. federal, state, or local, or non-U.S. law, rule, regulation, executive order, or policy, including, without limitation, any anti-money laundering law and the USA PATRIOT Act, and (2) such disclosure is not otherwise prohibited by law, rule, regulation, executive order, or policy;
- persons acting in a fiduciary or representative capacity on behalf of an investor or client, such as an IRA custodian or trustee of a grantor trust; and
- certain other persons to the extent authorized by you.
On all occasions when it is necessary for MPM to share your personal information with other parties, MPM will require that such personal information only be used for the limited purpose for which it is shared and will advise these companies not to further share your personal information with others, except to fulfill that limited purpose.
MPM does not disclose personal information about investors or clients except as may be required or permitted by law, rule, or regulation. MPM may disclose for a business purpose and has disclosed in the preceding twelve (12) months, personal information about investors and clients, including contact information, employment information, identification information, background information, and financial information to third parties, as listed above. In the preceding twelve (12) months, MPM has not sold any personal information to unaffiliated third parties.
INTERNATIONAL DATA TRANSFERS
Your personal information may be transferred to, stored, and processed in a country other than the one in which it was collected, including the United States, which country may not, or may not be, deemed to provide the same level of protection for personal information.
When we do so, and to the extent required by applicable data protection laws, we rely on appropriate or suitable safeguards, including:
- using standard contractual clauses approved by relevant authorities as ensuring adequate safeguards;
- obtaining your consent to transfer personal information after first informing you about the possible risks of such a transfer;
- when the transfer is necessary for the performance of a contract between you and MPM, or if the transfer is necessary for the performance of a contract between MPM and a third party, and the contract was entered into in your interest; and
- when the transfer is necessary to establish, exercise, or defend legal claims.
For more information on the safeguards MPM has in place, please contact us using the details below.
HOW LONG WILL MPM RETAIN YOUR PERSONAL INFORMATION?
When deciding how long to retain your personal information, MPM takes into account our legal and regulatory obligations, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information described above, and whether we can achieve those purposes through other means. MPM may also retain your personal information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.
COOKIES AND SIMILAR TECHNOLOGIES NOTICE
Cookies are small data files stored in your browser by a website. They transmit information about your use of the site to its operator or to third parties that placed the cookie. Some cookies are “session cookies” that expire when you close your browser, and others are “persistent cookies” that stay on your computer or mobile device until you delete them.
Our sites and applications may use both session and persistent cookies to enable you to sign in and use our sites and applications, store your preferences and settings within them; analyze how they perform, personalize your experience with them, provide interest-based advertising, facilitate social media interaction and for other lawful purposes. We may also use other similar technologies for these purposes, such as social media widgets that facilitate interaction with social media platforms, unique device identifiers, and third-party software embedded in our mobile applications. In some cases, these cookies and similar technologies are used by third parties.
Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.
If you do not accept our cookies, you may experience some inconvenience on our sites. For example, you may not be able to store preferences in our sites. If you disable cookies, certain features of our website may not work.
We welcome your questions and comments about privacy. Please contact us at email@example.com.