This Policy shall be effective for all customers from April 1, 2020.

Last updated: March 22, 2020

We at MaNe IDR (defined below) respect and protect the privacy of visitors to our websites and our customers. This Privacy Policy describes our information handling practices when you access our services, which include our content on the websites located at maneidr.com.

Please take a moment to read this Privacy Policy carefully. If you have any questions about this Policy, please submit your request via our Comment message form.

ACCEPTANCE OF THIS PRIVACY POLICY

By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.

OUR RELATIONSHIP TO YOU

You may be asked to provide personal information anytime you are in contact with us for the means of identification.

THE PERSONAL INFORMATION WE COLLECT

Personal information is data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties.

Information you provide to us

Please note that we may not be able to serve you as effectively or offer you our Services if you choose not to share certain information with us. Any information you provide to us that is not required is voluntary.

We may collect the following types of information from you:

Personal Identification Information: Full name, nationality, phone number and/or email.
Correspondence: Information provided to our support team or user research team.

Information we collect from you automatically

We receive and store certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and applications, provide you with a streamlined and personalized experience. Information collected automatically includes:

Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.

For example, we may automatically receive and record the following information on our server logs:

How you came to and use the Services;
Device type and unique device identification numbers;
Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
How your device interacts with our Sites and Services, including pages accessed and links clicked;
Broad geographic location (e.g. country or city-level location); and

Information collected from third parties

From time to time, we may obtain information about you from third party sources as required or permitted by applicable law. These sources may include:

Joint Marketing Partners & Resellers: For example, unless prohibited by applicable law, joint marketing partners or resellers may share information about you with us so that we can better understand which of our Services may be of interest to you.
Advertising Networks & Analytics Providers: We work with these providers to provide us with de-identified information about how you found our Sites and how you interact with the Sites and Services. This information may be collected prior to account creation – for more information on how you can manage collection of this data, please see our Cookie Policy.

HOW YOUR PERSONAL INFORMATION IS USED

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We generally use personal information to create, develop, operate, deliver, and improve our Services, content and advertising; and for loss prevention and anti-fraud purposes.

We may use this information in the following ways:

1) To provide Services

We process your personal information to provide the Services to you. For example, when you want a service to be provided to from us, we require certain information such as your identification and contact information.

2) To provide customer service

We process your personal information when you contact us to resolve any questions. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.

The following chart summarizes how we use the categories of personal information we collect from consumers:

We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as required under the applicable law, we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorisation. If you choose to so limit the use of your personal information, certain features or Services may not be available to you.

EEA Data Subjects

Legal Bases for Processing your Information

For individuals who are located in the European Economic Area, United Kingdom or Switzerland (collectively “EEA Residents”) at the time their personal data is collected, we rely on legal bases for processing your information under Article 6 of the EU General Data Protection Regulation (“GDPR”). We generally only process your data where we are legally required to, where processing is necessary to perform any contracts we entered with you (or to take steps at your request prior to entering into a contract with you), for our legitimate interests to operate our business or to protect companys or your, property, rights, or safety, or where we have obtained your consent to do so.

Marketing

Direct Marketing: Direct marketing includes any communications to you that are only based on advertising or promoting our products and services. We will only contact you by electronic means (email) based on our legitimate interests, as permitted by applicable law, or your consent. To the extent we can rely on legitimate interest under the applicable law, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, we will contact you by electronic means for marketing purposes only if you have consented to such communication. Direct marketing includes any communications to you that are only based on advertising or promoting our products and services.

We take care to allow your personal information to be accessed only by those who require access to perform their tasks and duties, and to share only with third parties who have a legitimate purpose for accessing it. MaNe IDR will never sell or rent your personal information to third parties without your explicit consent. We will only share your information in the following circumstances:

With service providers under contract who help with parts of our business operations. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else. Examples of the types of service providers we may share personal information with (other than those mentioned above) include:
Information Technology
Marketing

THIRD-PARTY SITES AND SERVICES

Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Please review the privacy notice of any third-party that will gain access to your personal information.

HOW WE PROTECT AND STORE PERSONAL INFORMATION

We understand how important your privacy is, which is why we maintain appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us.

We may store and process all or part of your personal and transactional information where our facilities or our service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

If you have reason to believe that your data is no longer secure, please contact us using the contact information provided in this Privacy Policy.

RETENTION OF PERSONAL INFORMATION

We store your personal information securely throughout the life of your Account. We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. Information about our typical retention periods for different aspects of your personal information are described below.

Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list to ensure we do not inadvertently market to you.
Information collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.

YOUR PRIVACY RIGHTS

Depending on applicable law where you reside, you may be able to assert certain rights related to your personal information identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, the company has absolute discretion in providing you with those rights.

Your rights to personal information are not absolute. Depending upon the applicable law, access may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.

Access and portability. You may request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to a potential fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. In certain circumstances, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another data controller.
Rectification of incomplete or inaccurate personal information. You may request us to rectify or update any of your personal information held by MaNeIDR that is inaccurate. You may do this at any time by logging in to your account and clicking the Profile or My Account tab.
Erasure. You may request to erase your personal information, subject to applicable law. If you close your Account, we will mark your account in our database as “Closed,” but will keep certain account information, including your request to erase, in our database for a period of time as described above. This is necessary to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account, and to comply with company’s legal obligations. However, if you close your account, your personal information will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.
Withdraw consent. To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of MaNeIDR’s processing based on consent before your withdrawal.
Restriction of processing. In some jurisdictions, applicable law may give you the right to restrict or object to us processing your personal information under certain circumstances. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Automated individual decision-making, including profiling. The company relies on automated tools to help determine whether a transaction or a customer account presents a fraud or legal risk. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.