In order to provide our customers the strongest privacy protection, we apply the standard set by the EU’s General Data Protection Regulations (“GDPR”). Accordingly, when we talk about personal information, we use the terms “Personal Data” and “processing” as they are defined in the “GDPR”.
Personal Data generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. MDGC will be the controller of your Personal Data processed in connection with the Services.
WHAT PERSONAL DATA DO WE COLLECT FROM YOU?
We collect Personal Data about you when you provide such information directly to us or when Personal Data about you is automatically collected in connection with your use of our Website or the Services.
Information we collect directly from you
We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:
- First and last name
- Email addresses
- Usernames for third party services (including Twitter, Facebook and Instagram)
- Credit/debit card/Paypal information
- Information we automatically collect when you use our Services
Some Personal Data is automatically collected when you use our Services, such as the following:
- IP address
- Device identifiers
- Web browser information
- Page view statistics
- Browsing history
- Usage information
- Transaction information (e.g. transaction amount, date and time such transaction occurred)
- Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.)
- Log data (e.g. access times, hardware and software information)
HOW DO WE USE YOUR PERSONAL DATA?
We process Personal Data to operate, improve, understand and personalise our Website and our Services. For example, we use Personal Data to:
- Create and manage user profiles
- Communicate with you about the Services
- Process orders
- Contact you about Service announcements, updates or offers
- Provide support and assistance for the Services
- Personalise website content and communications based on your preferences
- Meet contract or legal obligations
- Respond to user inquiries
- Fulfil user requests
- Comply with our legal or contractual obligations
- Resolve disputes
- Protect against or deter fraudulent, illegal or harmful actions
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
- Legitimate Interest: We also process Personal Data above when we believe it furthers our legitimate interests, examples of which include:
- Operation and improvement of our business, products and services
- Marketing of our products and services
- Provision of customer support
- Protection from fraud or security threats
- Compliance with legal obligations
- Completion of corporate transactions
- Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
- Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
HOW AND WITH WHOM DO WE SHARE YOUR DATA?
How and With Whom Do We Share Your Data?
- Payment processors
- Fraud prevention service providers
- Ad networks and partners
- Analytics service providers
- Hosting service providers
We also share Personal Data when necessary to complete a transaction initiated or authorised by you or provide you with a product or service you have requested, including to other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorised by you through the Services)
We also share Personal Data when we believe it is necessary to:
- Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
- Maintain the security of our products and services
We also share information with third parties when you give us consent to do so.
Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.
HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalised or aggregated form but not in a way that would identify you personally.
WHAT SECURITY MEASURES DO WE USE?
We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity, including by using data hosting service providers to host the information we collect.
Personal Data of Children
We acknowledge that some members of MDGC may be aged under the age of 18 and we may obtain Personal Data from them. If we learn that we have collected Personal Data from a child under age 18, we will endeavour to obtain consent from a parent or guardian. If that cannot be quickly obtained, we will delete that information as soon as possible. If you believe that a child under 18 may have provided us Personal Data, please contact us at email@example.com
What Rights Do You Have Regarding Your Personal Data?
You have certain rights with respect to your Personal Data, including those set forth below. To submit a request in respect of your rights, please email firstname.lastname@example.org. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardises the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary, to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by accessing your account profile.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by accessing your account profile.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilise some or all of our Services. Alternatively, in some cases where you withdraw consent, you may be unable to access the Website or our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about the Company’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State (if applicable).
TRANSFERS OF PERSONAL DATA
The Services are hosted and operated in Australia through the Society and its service providers, and if you do not reside in Australia, laws in the Australia may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to the Company in Australia and will be hosted on servers the geographic location of which shall be determined by the Society, and you authorise the Society to transfer, store and process your information to and in Australia, and possibly other countries.
QUESTIONS OR CONCERNS
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to email@example.com, and we will try to resolve your concerns.