This policy relates to visitors to the website and others who contact MMC on an ad hoc basis and sets out how MMC:
- Collects your information
- Use your information
- Communicates with you including for promotional updates
- Shares your information
- Stores your information
- Payment details
- Protects your information
- Keeps your information
We also set out your rights, how we may communicate changes to this policy and how you can contact us with privacy queries. If, over time, you become an investor, employee or your company becomes part of our portfolio different privacy policies will apply and we will inform of that.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By you contacting us and providing information to us you agree that this policy will apply.
For the purposes of UK data protection law, (the “Data Protection Law“), we, MMC, are the data controller.
Information we collect about you and how we use it:
We set out below examples of the categories of information we collect from you, how we collect this, the purpose for which we collect, and the lawful basis under which we are permitted to collect and process your information.
| What we collect | How we collect it | Use / Purpose of collection | Lawful basis for collection |
|---|---|---|---|
| Name and contact details | By telephone, may have been recorded, via website or email | If you call us or request information through the website to ask for information about our funds we will take your name and contact details in order to send that to you and be in contact | We have a legitimate interest in providing you with the requested information and making reasonable subsequent contact to assist you in deciding whether to invest with us. |
| Name, contact details and career history | Via website or email | You send us a copy of your CV when seeking employment with MMC or one of our portfolio companies | We have a legitimate interest in reviewing your CV to learn more about you and to consider whether there is a suitable job vacancy and to contact you. |
| Name and contact details | By telephone, may have been recorded, via website or email | You send us information about yourself and your company (or the company you are advising) for us to consider investing in the business | We have a legitimate interest in reviewing the information about you and the business to learn more about you and consider whether it might be a suitable investment for us and to contact you. |
| Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform | By cookies and analytic software. | To collect information about traffic to the website. | We have a legitimate interest in ensuring that you have the best experience using our website |
| Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page. | By cookies and analytic software. | To collect information about traffic to the website. | We have a legitimate interest in ensuring that you have the best experience using our website |
Some parts of our website (www.mmc.vc) may use a ‘cookie’, which is a small text file that is placed on your computer’s hard drive. The cookie captures no personally identifiable information. The website may use a cookie in order to log which pages you visit or to provide enhanced capabilities during your visit. You can set your browser to refuse to accept cookies; however if you choose to do this, some features of this website and others may not function properly.
From time to time, including but not limited to, when you voluntarily provide information to us, we may collect other categories of data from you.
Above we set out specific circumstances in which we collect your information how and why we collect this and our lawful basis for doing so. Many of the categories of information we collect primarily to allow us to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. We will always let you know if are relying on consent to process your personal data and you have a right to withdraw consent at any time.
Our promotional updates and communications
Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about our services and events that may interest you.
You can object to further marketing at any time by selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you, or by sending us an email to fundenquiries@mmc.vc.
How we share your personal information
We are very concerned to ensure that your personal information is only shared with third parties who process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. Our selected third parties may include:
- Organisations who support our business services. These include: those providing website and data hosting services (presenting including Dropbox, Slack, WordPress, Microsoft, Investran, Sugar CRM), our corporate nominee (presently Mainspring Fund Services), providing fulfilment services, distributing any communications we send (presently including MailChimp, PaperlessPost), supporting or updating marketing lists (presently including MailChimp, PaperlessPost), facilitating feedback on our services and providing IT support services (presently AM IT Services) from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your information to the extent necessary to perform their support functions.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy (this will not identify you as an individual)
- Business partners who provide services to you and with whom we have entered into agreements in relation to the processing of your personal data.
- Identification verification agencies for the purposes of assessing your identity
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
- If MMC Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of MMC Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
We will disclose your personal information to third parties:
In accordance with the below section, we may transfer your personal information to countries outside the UK. At present, the only country outside the UK to which personal information is sent is the United States of America.
Where we store your information
The data that we collect from you may be transferred to, and stored at, a destination outside the UK that may not be subject to equivalent Data Protection Law.
Where your information is transferred outside the UK, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.
We may transfer your personal information outside the UK:
- In order to store it.
- In order to enable us to provide goods or services to you and fulfill our contract with you. This includes order fulfillment and the provision of services by third parties (see above).
- Where we are legally required to do so.
- In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
If you have any questions about data transfer, please do contact us.
Payment Details
We do not take payment details.
How we protect your information
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data in transmission. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
From time to time, we may provide communications that contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
How long we keep your information
We retain personal data to allow us to consider the information you have provided to us and follow up with you if appropriate and will delete information on request. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
Your rights
You have the right under certain circumstances:
- to be provided with a copy of your personal data held by us;
- to request the rectification or erasure of your personal data held by us;
- to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal data, including the right to object to marketing (as mentioned above;
- to request that your provided personal data be moved to a third party.
- where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. You can also change your marketing preferences at any time as described above.
Your right to withdraw consent:
You can also exercise the rights listed above at any time by contacting us at fundenquiries@mmc.vc or on 020 7938 2220.
If your request or concern is not satisfactorily resolved by us, you may approach the Information Commissioner’s Office which is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Changes to this policy
Any changes we make to our privacy policy in the future will be posted on our website and, in relation to substantive changes or where required by law, will be notified to you in writing where required by Data Protection Law. This policy was last updated on 14 November 2022.
Contact Us
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to:
MMC Ltd.
FAO: LEGAL (PRIVACY)
24 High Holborn
London WC1V 6AZ
fundenquiries@mmc.vc