Last Modified: 10, April 2019
MGI Modus Operandi Capital Management Ltd (“Modus”, “we”, or “us”) value individual privacy, and we are committed to protecting individuals’ information.
This Privacy Notice (this “Notice”) describes the types of information we collect, how we collect information, what we do with information that we collect, and how you can contact us with any questions about our information practices or to access or request changes or updates to information concerning you.
Please review this Notice carefully to understand our practices and treatment of information. If this Notice is unacceptable to you or if you do not agree with our information practices, you may choose not to visit or use this website or any services offered through this website.
This Notice applies to information that we collect through our public website, at www.modusoperandicapital.com, and any of our other websites that provide a link to this Notice (collectively, the “Site”), from you as an individual user (“you”) of the Site.
This Notice does not apply to information collected by other means, or information collected by third parties, third-party websites, or content or applications of third parties, including any that may be linked to or accessible from or on the Site.
Information We Collect and How We Collect It
Information You Provide to Us. If you communicate with us through the Site, for example to request information from us, we may ask you to provide certain information about yourself, such as your name, email address, phone number, employer or organisation, professional role, or similar information. In these cases, you will know what information is collected through the Site because you will provide that information to us.
If there is information that you are required to provide to us or that we are required to collect, based on either law or contract, we will advise you of the requirement at the time we collect that information, and we will also provide information about any consequences of a failure to provide required information.
Information We Collect Automatically. As part of the standard operation of the Site, we automatically collect information from your computer or device, including IP address, domain name, referral or exit data (the last website that you visited before visiting the Site and the next website you visit afterwards, respectively), as well as browser and platform type (a Google browser or an Apple platform, for example). We also collect information about how you use the Site, such as the date and time of your visit, the amount of time you spend on the Site, how often you visit the Site, the areas or pages that you spend the most time on, and other click-stream data. Information collected automatically is generally statistical data and generally does not identify you personally.
In addition, with the assistance of our third-party partners and service providers, we may use technologies such as web beacons, tags, Flash cookies or HTML5 to collect or use information about visitors to the Site and their actions on the Site. For information about opting out of or managing the collection or use of such information, please see the section below regarding “Your Choices.”
The Site does not respond to “do-not-track” requests or similar browser settings.
How We Use Information We Collect
We use information that we collect, including your personal information, for the following purposes:
To present the Site and its contents to you.
To provide any information that you may access through the Site.
To maintain and improve our content, for example by analyzing usage to identify pages and topics of interest.
To respond to your questions or requests for information, or to fulfill any other purpose for which you provide your information to us through the Site.
To better understand how visitors use the Site and the performance of the Site, including measuring and monitoring user traffic and using aggregate statistical analysis, which informs future enhancements and changes to the Site, or by combining information collected through the Site with information about our customers collected by other means.
For any other purpose that we describe at the time we collect your information.
For any other purpose with your consent.
In addition to these uses, we may combine information about you that is collected through the Site with information about you from other sources.
Disclosure of Your Information
We may disclose aggregate statistical information about visitors to the Site, which does not identify individual users, without restrictions.
Personal information about you, that you provide or that we collect as described in this Notice, may be disclosed to third parties as follows:
To our subsidiaries and affiliates.
To agents and service providers who are bound by confidentiality obligations and who use the personal information only on our behalf.
To deliver any requested information or otherwise to fulfill a contractual obligation to you.
With your consent.
As otherwise described in this Notice.
We may also disclose your personal information:
As required by law, court order or legal process, including to respond to a subpoena, to respond to a government or regulatory request, or to cooperate with law enforcement investigations.
To enforce our contractual rights, take precautions against liability, investigate suspected or actual illegal activities, or to investigate and defend ourselves against third-party claims or allegations.
To a buyer or other successor in the event of a merger, restructuring, reorganisation, or other sale or transfer of some or all of our assets, including, but not limited to, as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about users of the Site is among the assets transferred.
When we believe that disclosure is necessary or appropriate to protect the rights, property, or personal safety of ourselves, our customers, or others.
Whenever we disclose personal information to a third party, we seek to minimise the disclosure to only information that is necessary for the purpose of that disclosure.
How Long We Hold Your Information
We will hold information about you that is collected through the Site for our internal business purposes unless you request otherwise.
We may also retain personal information about you for a reasonable time for backup, archival, reactivation or audit purposes, or as needed to comply with our legal obligations, resolve disputes or enforce our agreements. If you have any questions about how long we may keep personal information about you, please contact us via the link on the main website.
International Transfers of Personal Information
For the purposes described in this Notice, we may transfer information across borders, including from your country or jurisdiction to other countries or jurisdictions around the world, where applicable laws may not provide the same level of protection of personal information as the laws of the country or jurisdiction where you are located. In those cases, we take steps to ensure that information will be provided the same level of protection in the recipient country or jurisdiction.
By visiting or using the Site, you hereby consent to the transfer of your personal information to countries where applicable laws may not provide the same level of protection of personal information as the laws of the country or jurisdiction where you are located, including, without limitation, the United States, in accordance with this Notice.
Accessing and Requesting Changes to Your Information
If you wish to access, correct, update, or delete personal information about you, please contact us via the link on the main website. In responding to your request, we may request information from you and use information previously collected to verify your identity, or take other actions that we believe are appropriate.
Please understand that we may not be able to alter or delete your personal information if we are required under applicable law to maintain that information. We are also not obligated to comply with requests that are unreasonably burdensome or expensive, or with requests that would interfere with the rights of another individual. In some circumstances, we may charge a reasonable fee to fulfill your request.
You have certain choices about how your personal information is collected, used and shared. Although you may not be able opt out of all collection or use of personal information and still use the Site or our services, you can take steps to limit or control how your personal information is collected, used and shared.
Cookies. You can control or delete cookies, or otherwise manage cookies, through your browser or device settings. For more details, please visit https://www.allaboutcookies.org or https://www.aboutcookies.org. Please understand, however, that you may be unable to use all of the functionality of the Site or our services if you choose to reject cookies.
To learn more about cookies, please see our Cookies Statement at www.modusoperandicapital.com/privacy-policy.
We take reasonable steps and follow generally accepted industry data practices to protect personal information submitted to us from accidental loss and from unauthorised access, use, alteration, and disclosure. Unfortunately, there is no completely secure or error-free method of data transmission over the Internet, and we cannot guarantee the absolute security of your personal information.
The Site is not intended for children under the age of 13 and we do not knowingly collect or solicit personal information from children. If we learn that we have collected or received personal information from a child, we will delete that information.
If you believe that we may have any personal information about a child, please inform us by contacting us as provided in this Notice.
Changes to Our Privacy Notice
We may update this Notice to reflect changes to our information practices. If we make any material changes to how we treat the personal information of visitors to the Site, we will provide notice by updating the date the Notice was last revised. We encourage you to periodically review this page to learn of any changes we have made to this Notice.
Please feel free to contact us with any questions, comments, complaints, or suggestions regarding this Notice or our information practices. You can email us contact us via the link on the main website or by postal mail at:
Nicosia, Cyprus 109
For Residents of the European Economic Area
The following information is provided for residents of the European Economic Area, in case we may hold personal information about them.
Why We Are Able to Collect and Use Your Personal Information
We rely on our legitimate interests and the legitimate interests of our business partners as the legal basis for processing data concerning users of the Site who are residents of the European Economic Area (or “EEA”). Specifically, it is necessary for us to process personal data in order to pursue our legitimate interests in ensuring the proper operation and furthering our understanding of the Site and services accessed through the Site. Also, for people who use the Site or access services on behalf of one of our clients, we collect and process information as a necessary part of the services that we provide to our clients.
In some cases, where we ask for your consent to use information about you, your consent acts as the legal basis for our use of that data. In those cases, you have the right to withdraw your consent at any time. If you would like to withdraw your consent, please contact us as provided in this Notice under “Contact Us.”
Transfer of Your Personal Information Outside of the European Economic Area
For the purposes described in this Notice, we may transfer personal information out of the EEA to Guernsey, which may not have laws that provide the same level of protection of personal information as the laws of the EEA, or where the European Commission has not issued any formal decision that these countries provide an adequate level of protection of personal information.
In order to ensure that adequate protections are provided for personal information, we will perform these transfers of personal information outside of the EEA under standard contractual clauses approved by the European Commission, as permitted pursuant to Article 46(2)(d) and (5) of the General Data Protection Regulation (Regulation 2016/679).
If you would like more information about our transfer of data outside of the EEA or copies of relevant documents, please contact us as provided in this Notice under “Contact Us.”
Rights of Residents of the European Economic Area
If you are a resident of a country within the EEA, you have certain individual rights under the General Data Protection Regulation (Regulation 2016/679) or related local legislation. You have the right to obtain confirmation from us as to whether or not we process personal information about you. And if we do process your personal information, your other rights include:
The right to access your personal information and receive certain information about our privacy practices.
The right to have us correct incorrect information that we hold concerning you, or to complete incomplete information.
The right to request that we erase information concerning you and to have that information erased under certain conditions.
The right to restrict our processing of information concerning you under certain conditions.
The right to object to our processing of information concerning you under certain conditions.
The right to object to our use of information concerning you for direct marketing, or for profiling relating to direct marketing.
The right to receive personal information that you provided to us in a structured and commonly-used, electronic format and the right to transmit that information to another entity, in certain situations.
The right to object to decisions based on automated processing of information concerning you, if those decisions have legal effects or similarly significant effects.
If you would like to exercise any of these rights, please contact us as provided in this Notice under “Contact Us.”
Please understand that, before responding to your request, we may ask you for additional information in order to verify your identity.
We may not be obligated to fulfill your request to exercise your rights if we are restricted by applicable local laws, or if fulfilling your request would negatively impact the rights and freedoms of other individuals.
We may decline to fulfill requests or charge a reasonable fee based on our administrative costs if requests are clearly excessive or unfounded, including in cases where requests are repetitive.