Privacy Policy

Your Data - Your Privacy

MVSI Pty Ltd, and its operating subsidiaries (“MVSI” or “we”) are committed to your right to privacy. Protecting our users’ privacy is a core value of MVSI, and we take precautions to ensure the protection of our Users’ personal data as well as to comply with applicable privacy and data protection legislation within the jurisdictions we operate in. We respect the fact that our Users’ personal data and original content are their own, and have implemented mechanisms to ensure you have control over your data and content.

This Privacy Policy (the “Privacy Policy”) which is incorporated by reference in our Terms of Use, governs the processing and transfer of data collected in connection with our website (the “Site”) and/or the services available through the Site or otherwise provided by MVSI, including any MVSI Services (the “Services”), to each person, including Customers, Customers’ users and End-Users accessing or using the Site and/or the Services (the “User” or “you”). Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms of Use.

If you choose to use the Site and/or Services, or otherwise provide data to us, you explicitly agree to the use of such data in accordance with this Privacy Policy.

We are committed to being transparent about how we collect, use, share, and protect personal data.

We aim to provide information about our data processing activities in clear, plain, and accessible language so individuals can understand what personal data we use, why we use it, and what rights they have in relation to it.

If any part of this Privacy Policy is unclear, or if you would like further information about how we process personal data, please contact us using the details set out below.

You may not use the Site or submit any data through the Site and/or Services if you do not agree to any of the terms hereunder. This Privacy Policy shall not be construed in any manner to derogate from the Terms of Use or any other agreement made by and between MVSI and you.

ISO 27001 and Compliance with Data Privacy Law

MVSI is an ISO 27001 certified company, and we maintain a comprehensive Information Security Management System (ISMS) for the protection of information.

MVSI and its subsidiary companies comply with applicable privacy and data protection laws in the jurisdictions in which we operate, including the UK GDPR, the EU GDPR, the EU Digital Operational Resilience Act (DORA), Australia’s Privacy Act 1988, Singapore’s Personal Data Protection Act 2012 (PDPA), Canada’s applicable privacy laws, and relevant US federal and state privacy requirements. We apply these same privacy, security, and transparency principles across every jurisdiction in which we operate.

In short, we do not share your information for any purpose other than for the sole and exclusive purpose for which it was collected, and we will never sell your information under any circumstances.

The Highlights

• You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. If you choose not to, we may not be able to provide you with the Services.
• Our Services are intended for Users over the age of 16 or equivalent minimum age for providing consent to processing of Personal Data in the relevant jurisdiction. Children under such age are not permitted to register to or use the Services. If you are under such age you should cease to use the Services immediately. 
• You may be entitled to request to review, amend, erase or restrict the processing of your Personal Data, pursuant to applicable law. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Services may be restricted.
• We do not sell, trade, or rent Users’ Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Services to our Users, or other limited circumstances specified herein.
• We hold your personal data for a limited time, the time being determined by the legislation under which it was collected. Information that is no longer required to be held by law is deleted.
• If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Policy, please contact our Data Protection Officer using the details set out below.

The Detail

1. What is Personal Data, and what data is collected about me by MVSI?

“Personal Data”, means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, billing information, etc.
Non-Personal Data. 

We collect non-Personal Data regarding Users concerning their use of the Services, such as the scope, frequency, latency, pages accessed, what and when a User views or interacts with content and materials displayed through our Services, device identifiers, and other technical information regarding the device used to access the Services, such as model, operating system, etc.

Personal Data and Sensitive Data: In connection with User’s interaction with the Site and Services, we log visitor’s domain and IP address automatically we also collect the following Data:

MVSI collects and processes the following personal data regarding its Customers:

Contact Details. In order to provide the Customer with our Services or when a Customer registers to our Services we collect Customer’s full name (in case the Customer is an individual) and contact details of the Customer’s focal point person, such information includes: phone number and email. 

KYC and AML data. In order to fulfill our legal obligations to prevent fraud and money laundering, we will obtain information regarding the Customer or the Customer’s shareholders (if the Customer is a legal entity that is not an individual) during the onboarding process or afterwards, such information includes identification number (passport, I.D. number or driving license number), date of birth, residence country, citizenship country, email address, phone and mobile number, face snapshot and video, and copy of the identification document; 

Special Categories of Personal Data:

As part of our requirements to fulfill our legal obligations to prevent fraud and money laundering we may collect Personal Data included in Special Categories of Personal Data (i.e. sensitive data) required under KYC and AML regulations, (during the onboarding process or after that), such data includes information regarding whether the Customer or its shareholders are politically exposed persons (PEPs). 

MVSI Systems. MVSI will collect certain information regarding the MVSI System users, including their account details, credentials, phone number, and employer’s name (e.g. the Customer). For more information regarding the use of the MVSI Systems please review our MVSI Systems Terms and Conditions. 

Please refer to our DPA in order to review the additional provisions related to the processing of Personal Data in connection with the Services provided to the Customers by MVSI. 

Site Visitors. When you visit our site we log your domain and IP address. 

Contact Us and Support. If you contact us for support, business or refund services via the “Contact Us” and/or “Support” features, we will collect certain information regarding you, such as your full name, your email, your phone number, your company (if applicable to you), country, the content of your message, etc. Please note, that the Services may contain links to other websites maintained by third parties, which may not be governed by this Privacy Policy. This Privacy Policy does not apply to the practices of entities which are not controlled, owned, employed, or managed by MVSI.

Sources of Personal Data:

Depending on the nature of our relationship with you and the services we provide, we may collect personal data about you from a range of sources.

These sources may include:

• information you provide directly to us
• employers, clients, customers, intermediaries, or other organizations where you apply for, access, or use a service, or where you are considered for an opportunity
• referees, where relevant and permitted by law
• publicly available sources, such as professional networking sites, business websites, and public records
• credit reference agencies, where required for consumer credit, identity, fraud prevention, affordability, compliance, or due diligence checks
• third party service providers and partners that support screening, verification, onboarding, compliance, fraud prevention, recruitment, and related business processes

2. What will MVSI do with my Personal Data? 

Non-Personal Data. Non-Personal Data is used mainly for analysis in order to constantly improve and maintain our Services, including among others, in order to measure and understand the level of engagement to our services, for general business analytics and in order to provide a more personalized experience and tailored content, for ensuring the technical functioning of our network, to help prevent fraudulent use of our Services and for developing new services. 

Personal Data. Personal Data is used only for the following limited purposes: 

• To provide the Services to the Customers and Users including its features and functionalities; 
• To communicate with Users regarding customer service issues or to provide updates with respect to material changes to this Privacy Policy or our Terms of Use.
• Responding to questions or comments and to help resolve any problems. 
• For the purposes of our legitimate interests, to the extent permitted under applicable law. 
• Depending on the product, service, jurisdiction, and the nature of our relationship with you, to carry out onboarding, identity verification, fraud prevention, compliance, due diligence, creditworthiness assessment, affordability assessment, and risk management activities.
• To protect the security or integrity of our databases and the Services, and to take precautions against legal liability. 
• To comply with any applicable law and assist law enforcement agencies and competent authorities, when we have a good faith belief that our cooperation with them meets the applicable legal standards. 
• To improve the Services, and to develop new features, products and services.
• To improve your experience on the Site and customize our Services to your interests. Please note that we may also use Personal and non-Personal Data in connection with automatic analysis of our users’ behavior.
• We do not share personal data with unrelated third parties outside these principles.

Credit Reference and Third-Party Data Checks

Where relevant to our services, onboarding, verification, compliance, fraud prevention, affordability, due diligence, or risk management processes, we may obtain personal data about you from credit reference agencies and other third-party data providers.

This may include information used to help verify identity, assess risk, prevent fraud, support compliance activities, and meet legal or regulatory obligations.

Further information about these checks, including the types of data involved, the third-party providers we may use, and links to relevant third-party privacy notices, is available in our Consumer Data and Credit Checks Notice.

3. Does MVSI use cookies? 

Yes, we use data files such as cookies, pixel tags, “Flash cookies,” or other local storage files provided by your browser or associated applications (“Cookies”). We use these technologies in order to recognize you as a user; customize our Services, content, and advertising; measure promotional effectiveness; help ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across our Site and Services. Cookies can be placed on your device by the website operator such as MVSI, when You visit our Site, such Cookies constitute – “first party” Cookies, or by a party other than MVSI, in which case the Cookies will constitute – “third party” Cookies. Cookies can be differentiated by their time of use: “Session Cookies” are Cookies that exists between the time you visit the Site and the time you ended the particular browsing session. Session Cookies expire and are automatically deleted when you close your internet browser. “Persistent Cookies” are Cookies that stay on your device – they do not expire and are not automatically deleted when you close your browser.

The length of time Persistent Cookies stay on your device varies from Cookie to Cookie. We and third parties use Persistent Cookies for a variety of purposes, such as to store your preferences so that they are available for the next visit, to keep a more accurate account of how often You visit our Site, how often you return, how your use of our Site may vary over time, and the effectiveness of advertising efforts. You may at any time program your browser to block Cookies, but please be aware that such blocking may prevent us from providing some or all of the Services to You. These cookies help us track how visitors use the Site and our Services.

If you do not wish to receive Cookies from us, other than strictly necessary technical Cookies, you may follow the instructions for opting out of such Cookies on our Site or App, or contact us using the details set out below.

If you have any questions about how we use Cookies that are not answered in this statement, please contact us using the details set out below.

4. How do I control my Personal Data?

Reviewing and amending your Personal Data. You are entitled to review your Personal Data. You may exercise this right by sending us a request in connection with your Personal Data. In the event any Personal Data is incorrect or outdated, you may update and correct such data by providing us with appropriate notification. 

Right of erasure and restriction. You may also be entitled to request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law. 

Personal Data Portability of Personal Data. To the extent applicable to you and to the Services, you may request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law. 

Retention of Personal Data. We keep personal data only for as long as necessary for the purposes for which it was collected, including to provide services, manage our relationship with individuals and organizations, comply with legal, regulatory, tax, accounting, audit, and reporting requirements, resolve disputes, enforce our agreements, and protect our legal rights.

The retention period will depend on the type of personal data, the reason we collected it, and any specific legal or regulatory obligations that apply.

Personal data used for credit reference, identity verification, fraud prevention, or affordability checks is retained only for as long as necessary for those purposes and any related legal, regulatory, audit, or compliance requirements, after which it will be securely deleted, anonymized, or otherwise disposed of in accordance with our retention and security procedures.

Non-Personal Data and statistical anonymized data may be retained by us without limitation.

5. Will MVSI Share my Personal Data?

Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain any Personal Data and is used to develop content and services for our Users and clients. We share Personal Data only under the following limited circumstances: 

We share Personal Data with our clients when we have gathered that data on their behalf for the purposes of compliance verifications. 

End-Users Data. We share Personal Data related to End-Users with our Customers in order to provide you the Services. The privacy and security practices of the Customers are not covered by this Privacy Policy, and MVSI accepts no responsibility or liability for the privacy or security practices or the content of such applications. 

All Users. MVSI operates with multiple suppliers in various fields of activity with respect to the Site and Services. Such third parties assist MVSI in operating the Site and Services, conducting our business, expanding our business or servicing you, and for personalizing your experience of the Services, such third parties include, inter alia, service providers in the following fields: 

• Technology; 
• Verification Services; 
• Anti money laundering and Know Your Customer services;
• Credit reference, identity verification, fraud prevention, affordability assessment, and compliance data providers;
• Cloud Storage Services; 

To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.

6. What is the lawful basis under which MVSI processes Personal Data? 

Certain processing activities conducted by us are based on the necessity of such activities for the performance of the understandings between us and our Users. For example, if we are verifying your identity, you are an End-User for whom we need to gather identity information from in order to provide the service. 

Other processing activities are based on the grounds that they are necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subjects which require protection of Personal Data. 

Where we rely on legitimate interests as a lawful basis for processing, those legitimate interests may include operating our business, providing and improving our services, fulfilling contractual obligations, ensuring system and data security, preventing fraud, supporting audit and compliance activities, verifying identity, assessing creditworthiness or affordability where relevant, and protecting third party data, including data obtained from credit reference agencies and data providers.

We consider and balance these interests against the rights and freedoms of individuals and apply appropriate safeguards to protect personal data.

There may be certain processing activities based on your consent to this Privacy Policy. In connection with such activities, you may withdraw your consent by contacting us using the details set out below. Please note that in the event you rescind your consent to the processing of Personal Data, we may not be able to provide you with some or all of the Services. 

7. Will MVSI transfer my Personal Data internationally?

MVSI is a global company with offices all over the world. Our databases are located currently in Germany, UK, Australia and in the US. Some of our processing activities are conducted in each of these centers. The European Commission has decided that Australia and the US ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data to Australia and the US is lawful and does not require any specific authorization. 

Any future transfer of Personal Data outside the EU to a third country shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our Users’ rights. 

8. Complaints

If you are dissatisfied with how we collect, use, or protect your personal data, you have the right to lodge a complaint with a relevant data protection, privacy, or supervisory authority in the jurisdiction where you live, work, or where the relevant conduct took place.

9. Automated Decision-Making and Profiling

We may use automated systems, tools, or profiling techniques to support certain business processes, such as risk assessment, fraud prevention, identity verification, onboarding, screening, record matching, or compliance activities.

These tools may analyze personal data using predefined rules, models, or criteria to generate indicators, flags, scores, matches, recommendations, or outcomes that support or, in some cases, determine aspects of our decision-making processes.

In some circumstances, this may result in decisions being made by automated means, including in connection with onboarding, verification, fraud prevention, compliance, or risk assessment processes, where predefined criteria are met.

Where automated decision-making is used, we will do so in accordance with applicable law. Where required, individuals may have the right to request human intervention, express their point of view, and challenge a decision made solely by automated means.

If you would like more information about how these processes apply to you, please contact us using the details set out below.

10. Will I receive SPAM from MVSI?

We may send users of the Services, with information on new products, features, activities, services and periodic announcements or newsletters. By accepting this Privacy Policy you hereby provide us with your explicit, written consent to receive marketing communications. You may at any time choose to opt-out and to not receive these communications, by contacting us using the details set out below. 

11. Persons under 16

Our Site and the Services provided through it are intended for a general audience Site which is not directed to persons under 16 years old. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, he or she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 16 years old. If we become aware that a person under 16 years old has provided us with Personal Data, we will delete such data from our databases. 

12. How does MVSI protect your data? 

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information in accordance with the applicable law. We adopt appropriate and generally accepted data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Data. In particular, your payment information is secured in accordance with the international standards of ISO 27001.

ISO 27001 is a specification for an information security management system (ISMS). An ISMS is a framework of policies and procedures that includes all legal, physical and technical controls involved in an organization's information risk management processes.

13. Contact us and Data Protection Officer

If you have any questions about this Privacy Policy, our use of your personal data, or your data protection rights, you may contact us at DPO@mvsi.com.

Our Data Protection Officer is:
Daniel Sheahan
Email: DPO@mvsi.com

14. Questions or concerns regarding privacy

If you have any questions or concerns regarding privacy issues, this Privacy Policy, our use of your personal data, or your data protection rights, please contact us using the details set out in Section 13. We will make every effort to address your concerns without undue delay.

MVSI may, at any time and from time to time, modify this Privacy Policy. Modifications to this Privacy Policy will be posted on the Site, and shall be effective as of the date in which they are posted on the Site. You are also entitled to file a complaint with the appropriate data protection or supervisory authority if you have concerns about how we handle your privacy or Personal Data.

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