Privacy Policy

Last updated January 01, 2023

This privacy statement for Mfinity (the “Company,” “we,” “us,” or “our”) explains how and why we might gather, store, use, and/or share (or “process”) personal information when you use our services (the “Services”), such as when you:

• Visit our website at http://www.themfinity.com, or any website of ours that links to this privacy Policy
• Engage with us in other related ways, including any sales, marketing, or events

Concerns or questions? Your privacy rights and options will become clearer to you after reading this privacy Policy. Use of our Services is prohibited if you disagree with our rules and procedures. Please email us at info@themfinity.com if you have any more queries or worries.

SUMMARY OF KEY POINTS

The privacy policy’s key points are summarised below, but you may read our table of contents below to identify the specific part you’re interested in for more information on any of these subjects.

What types of personal data do we process? Depending on how you engage with Mfinity and the Services, the decisions you make, and the services and products you use, we may process personal information when you visit, utilise, or browse our Services.

Do we handle any highly sensitive personal data? Sensitive personal data is not processed by us.

Do we get any information from outside sources? We could get data from outside sources including social media networks, public databases, and marketing partners.

What steps do we take to process your data? We process your information for the purposes of delivering, enhancing, and managing our Services, keeping in touch with you, security and fraud prevention, and legal compliance. With your permission, we may use your information for other reasons. We only process your information when we have a good cause to do so under the law.

What circumstances and people do we share personal information with? In some circumstances and with particular third parties, we could disclose information.

How do we safeguard your personal information? To secure your personal information, we have organisational, technical, and procedural processes and procedures in place. We cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties won’t be able to circumvent our security and improperly collect, access, steal, or modify your information because no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.

What rights do you have? Depending on where you are based legally, the privacy legislation that is in effect may indicate that you have certain rights with regard to your personal data.

What rights may you exercise? Filling out our data subject request by getting in touch with us is the simplest method to exercise your rights. Any request will be taken into account, and we’ll follow any applicable data protection rules in doing so.

Would you want to know more about how Mfinity uses the data we gather? Please read the warning in its entirety.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO WE MAKE UPDATES TO THIS POLICY?
14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
16. WHAT INFORMATION DO WE COLLECT?

Personal information you ’re providing us

In short: we gather personal information that you supply to us.

We gather personal information that you voluntarily supply to us when you show an interest in learning more about us or our products and services, when you participate in activities on the Services, or otherwise when you contact us.

You Provided Personal Information. The personal information we collect is determined by the context of your interactions with us and the Services, the choices you make, and the goods and features you use. The following types of personal information may be collected:

• names
• phone numbers
• email addresses
• mailing addresses
• job titles
• usernames
• contact preferences
• contact or authentication data

Information that is sensitive. We do not handle any sensitive information.

All personal information you provide to us must be true, complete, and accurate, and you must notify us if any of this information changes.

Additional sources of information

In summary, we may obtain limited information from publicly accessible databases, marketing partners, and other third-party sources.

We may receive information about you from other sources, such as public databases, joint marketing partners, affiliate programmes, data suppliers, and other third parties, to improve our ability to provide relevant marketing, offers, and services to you and to update our records. For the sake of targeted advertising and event promotion, this information comprises postal addresses, job titles, email addresses, phone numbers, intent data (or user activity data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles.

2. HOW DO WE PROCESS YOUR INFORMATION?

In short: we process your information to offer, improve, and manage our Services, interact with you, for security and fraud protection, and to comply with the law. We may also use your information for other purposes with your permission.

We process your personal information for a variety of purposes based on how you engage with our Services, including:

• To provide and enable the provision of services to the user. We may use your information to provide you with the service you have requested.
• Respond to user enquiries and provide user help. We may use your information to reply to your enquiries and resolve any potential problems with the desired service.
• To send you administrative information. We may use your information to send you information about our products and services, updates to our terms and conditions, and other material of a similar nature.
• To process and manage your orders. We may use your information to fulfil and manage orders, payments, refunds, and exchanges placed via the Services.
• To allow for user-to-user contact. If you choose to utilise any of our offers that allow you to communicate with another user, we may process your information.
• To solicit input. We may use your information to solicit feedback and contact you about your usage of our Services.
• To send you marketing and promotional materials. We may use the personal information you supply us for marketing purposes if it is consistent with your marketing choices. You can unsubscribe from our marketing mailings at any time. See “WHAT ARE YOUR PRIVACY RIGHTS?” below for further information.
• To provide you with tailored advertising. We may use your information to create and show personalised content and advertising based on your preferences, location, and other factors.
• To safeguard our services. We may use your information to monitor and prevent fraud as part of our efforts to make our Services safe and secure.
• Identifying use patterns. We may process information about how you use our Services in order to better understand how we might enhance them.
• To assess the efficacy of our marketing and promotional initiatives. We may use your information to better understand how to offer relevant marketing and promotional campaigns to you.
• To safeguard or protect a person’s critical interests. We may use your information to save or defend an individual’s critical interests, such as preventing injury.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: we only process your personal information when we believe it is necessary and have a valid legal reason (i.e., legal basis) to do so under applicable law, such as with your consent, to comply with laws, to provide you with services, to enter into or fulfil contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

This section applies to you if you live in the EU or the United Kingdom.

The General Data Protection Regulation (GDPR) and the UK GDPR compel us to clarify the legal basis on which we treat your personal data. As a result, we may treat your personal information on the following legal bases:

• We may handle your information if you have granted us permission to use your personal information for a specific purpose (i.e., consent). You have the right to withdraw your permission at any time.
• Contract performance. We may handle your personal information if we feel it is required to fulfil our contractual duties to you, such as delivering our Services, or if you request it prior to entering into a contract with us.
• Interests that are legitimate. We may handle your information if we feel it is reasonably required to further our legitimate business purposes, and such interests do not outweigh your interests or basic rights and freedoms. For example, we may use your personal information for some of the following purposes:

• Inform users about special deals and discounts on our products and services.
• Create and deliver personalised and relevant advertising material to our users.
• Analyze how our Services are being utilised so that we may enhance them in order to engage and retain people.
• Help us with our marketing efforts.
• Diagnose issues and/or prevent fraudulent behaviour
• Learn how our customers utilise our goods and services so that we can enhance the user experience.

• Obligations under the law. We may handle your information in order to comply with our legal duties, such as cooperating with a law enforcement authority or regulatory agency, exercising or defending our legal rights, or disclosing your information as evidence in litigation in which we are engaged.
• Important considerations. We may handle your information if we believe it is essential to safeguard your vital interests or the vital interests of another person, such as in instances involving possible risks to anyone’s safety.

This section pertains to you if you live in Canada.

We may handle your information if you have given us particular permission (i.e., express consent) to use your personal information for a specific purpose, or if your permission may be inferred from the circumstances (i.e., implied consent). You have the right to withdraw your permission at any time.

In some extraordinary instances, we may be legally entitled to handle your information without your agreement under relevant legislation, such as:

• If collecting is obviously in an individual’s best interests and consent cannot be acquired in a timely manner For investigations, fraud detection and prevention
• For commercial transactions if specific requirements are satisfied
• If it is contained in a witness statement and collection is required to evaluate, process, or settle an insurance claim
• Identification of wounded, unwell, or deceased people and communication with next of family
• If we have reasonable reasons to think that an individual has been, is, or may be a victim of financial abuse, we will investigate.
• If it is reasonable to suppose that collection and use with consent will jeopardise the availability or accuracy of the information, and the collection is appropriate for purposes linked to investigating a breach of an agreement or a violation of Canadian or provincial laws.
• If disclosure is necessary to comply with a subpoena, warrant, court order, or court regulations governing record production,
• If it was created by an individual in the course of their work, business, or profession, and the collection is consistent with the objectives for which the information was created,
• If the information is publicly available and required by law,

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: we may disclose information in the scenarios specified in this section and/or with the third parties listed below.

In the following circumstances, we may need to share your personal information:

• Transfers of business. We may disclose or transfer your information as part of or during the course of any merger, sale of corporate assets, financing, or purchase of all or a portion of our business by another firm.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may gather and keep your information using cookies and other tracking technologies.

We may collect or store information using cookies and other tracking technologies (such as web beacons and pixels). Our Cookie Policy contains detailed information on how we use such technologies and how you may refuse specific cookies.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: Your information may be transferred, stored, and processed in countries other than your own.

Our servers are based in the United States of America. If you access our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us and third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above) in the United States and other countries.

If you reside in the European Economic Area (EEA) or the United Kingdom (UK), these countries may not have data protection regulations or other comparable rules that are as extensive as those in your country. However, we will take all necessary precautions to secure your personal information in line with this privacy Policy and current legislation.

European Commission’s Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We store your information for as long as is necessary to fulfil the objectives mentioned in this privacy policy, unless otherwise required by law.

We will only store your personal information for as long as it is required or authorised by law, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). This policy has no requirements that we preserve your personal information for more than one year.

When we no longer have a legitimate business need to process your personal information, we will either delete or anonymize it; if this is not possible (for example, because your personal information is stored in backup archives), we will securely store it and isolate it from further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We want to safeguard your personal information using a system of organisational and technical security safeguards.

We have set up appropriate and acceptable technological and organisational security measures to safeguard the privacy of any personal information we process. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be completely secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to circumvent our security and improperly collect, access, steal, or modify your information. Although we will do our best to secure your personal information, you are responsible for transmitting personal information to and from our Services. You should only use the Services in a safe context.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not intentionally collect or advertise to children under the age of 18.

We do not intentionally collect or advertise to children under the age of 18. By using the Services, you signify that you are at least 18 years old or that you are the parent or guardian of a minor dependent and consent to the use of the Services by such minor dependent. If we discover that personal information from users under the age of 18 has been obtained, we will deactivate the account and take reasonable steps to erase such data from our databases as soon as possible. Please notify us at info@themfinity.com if you become aware of any data we may have obtained from minors under the age of 18.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), the United Kingdom (UK), and Canada, you have more access to and control over your personal information. You have the option to examine, alter, or cancel your account at any time.

You have specific rights under relevant data protection legislation in some locations (such as the EEA, the UK, and Canada). These may include the right to I seek access to and a copy of your personal information, (ii) request rectification or deletion of your personal information, (iii) restrict the processing of your personal information, and (iv) data portability, where applicable. In some cases, you may be able to object to the processing of your personal information. You can make such a request by contacting us using the information in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below.

Any request will be considered and acted within compliance with relevant data protection legislation.

If you reside in the EEA or the UK and feel we are improperly processing your personal information, you have the right to file a complaint with your local data protection supervisory body. Their contact information may be found at https://ec.europa.eu/justice/data-protection/bodies/authorities/index en.htm.

If you reside in Switzerland, you can find contact information for the data protection authorities here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: You have the right to withdraw your consent at any time if we are relying on your consent to handle your personal information, which may be express or implicit consent depending on the applicable legislation. You have the right to withdraw your permission at any time by contacting us using the information provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below.

Please keep in mind that this will not impact the lawfulness of the processing prior to its withdrawal, nor will it affect the processing of your personal information done in reliance on legitimate processing grounds other than consent, where applicable.

Unsubscribing from marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages we send, or contacting us using the information provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below. After that, you will be removed from the marketing lists. However, we may continue to contact you for non-marketing purposes, such as sending you service-related messages that are required for the administration and use of your account, responding to service requests, or otherwise.

Cookies and comparable technologies: By default, most Web browsers allow cookies. If you choose, you can typically configure your browser to delete and refuse cookies. Certain features or services of our Services may be affected if you opt to remove or reject cookies. Visit http://www.aboutads.info/choices/ to opt out of interest-based advertising by advertisers on our Services.

If you have any concerns or complaints concerning your privacy rights, please contact us by email at info@themfinity.com.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers, as well as some mobile operating systems and applications, contain a Do-Not-Track (“DNT”) option or setting that you may use to express your privacy choice not to have data about your online browsing activity monitored and collected. No standardised technical standard for identifying and executing DNT signals has been developed at this time. As a result, we presently do not respond to DNT browser signals or any other technique that expresses your preference not to be tracked online. If an online tracking standard is adopted that we must follow in the future, we will notify you in an updated version of this privacy policy.

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you reside in California, you have certain rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, allows our California users to request and obtain information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes, as well as the names and addresses of all third parties with whom we shared personal information in the immediately preceding calendar year, once a year and free of charge. If you are a California resident and would want to make such a request, please send it to us in writing at the address shown below.

If you are under the age of 18, live in California, and have a registered account with the Services, you have the right to have undesired data that you publicly post on the Services removed. To request the removal of such data, please contact us using the information given below, including your email address and a declaration that you live in California. We will ensure that the data is not publicly visible on the Services, but please be aware that it may not be totally or completely erased from all of our systems (e.g., backups, etc.).

CCPA Privacy Policy

A “resident” is defined as follows in the California Code of Regulations:

(1) any individual who is in the State of California for a purpose other than a temporary or transitory one; and

(2) any individual who is domiciled in the State of California but is outside the State of California for a temporary or transitory one.

All other people are classified as “non-residents.”

If this term of “resident” applies to you, we must follow specific rules respecting your personal information.

What types of personal information do we gather?

In the last twelve (12) months, we have acquired the following types of personal information:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	NO
B. Personal information categories listed in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	YES
C. Protected classification characteristics under California or federal law	Gender and date of birth	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements	NO
G. Geolocation data	Device location	NO
H. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	YES
J. Education Information	Student records and directory information	NO
K. Inferences drawn from other personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	NO
L. Sensitive Personal Information		NO

We will use and maintain the collected personal information as necessary to perform the Services or for the following purposes:

• Category B – 1 year
• Category I – 1 year

We may also collect additional personal information outside of these categories when you contact with us in person, online, by phone, or by letter in the context of:

• Getting assistance from our customer service channels;
• Participation in customer satisfaction surveys or contests; and
• To make our Services more accessible and to reply to your queries.

How will we use and distribute your personal information?

This privacy policy contains further information about our data collecting and sharing methods.

You may reach us by email at info@thmfinity.com or by using the contact information listed at the bottom of this article.

If you use an authorised agent to exercise your right to opt out, we reserve the right to decline your request if the authorised agent fails to provide proof that they are legally allowed to act on your behalf.

Is your information going to be shared with anybody else?

We may share your personal information with our service providers in accordance with the terms of a documented contract between us and each service provider. Each service provider is a for-profit firm that processes information on our behalf while adhering to the CCPA’s strong privacy protection responsibilities.

We may use your personal information for internal company objectives, such as technology development and demonstrative research. This is not seen as “selling” your personal information.

In the previous twelve (12) months, Mfinity did not disclose, sell, or exchange any personal information with other parties for business or commercial purposes. Mfinity will not sell or distribute personal information about website visitors, users, or other consumers in the future.

Your privacy and data protection rights

Right to request data deletion — Data deletion request

You have the right to request that your personal information be deleted. If you request that we delete your personal information, we will do so, subject to certain legal exceptions, such as (but not limited to) another consumer exercising his or her right to free speech, our compliance obligations resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request for information

You have a right to know depending on the circumstances:

• whether we gather and utilise your personal information;
• the types of personal information that we gather;
• the reasons for which the gathered personal information is utilised;
• if we sell or share personal information with other parties;
• the types of personal information we sold, exchanged, or revealed for commercial purposes;
• the types of third parties to whom personal information was sold, transferred, or given for commercial purposes;
• the business or commercial reason for collecting, selling, or exchanging personal information; and
• the exact pieces of personal information we obtained about you.

We are not required by law to give or remove de-identified consumer information in response to a consumer request, or to re-identify individual data to validate a consumer request.

Non-Discrimination in the Exercise of Consumer Privacy Rights

We will not treat you unfairly if you exercise your privacy rights.

Right to Restrict the Use and Disclosure of Personally Identifiable Information

We do not process sensitive personal information about our customers.

Verification process

When we get your request, we will need to verify your identification to ensure you are the same individual whose information we have in our system. These verification attempts necessitate us requesting information from you in order to compare it with information you have already supplied us. For example, depending on the type of request you submit, we may ask you for specific information so that we can match the information you provide with the information we already have on file, or we may contact you via a communication method (e.g., phone or email) that you have previously provided to us. Other types of verification may also be used depending on the circumstances.

We will only use the personal information you supply in your request to validate your identity or authorisation to make the request. We will avoid asking for more information from you for verification reasons as much as feasible. However, if we are unable to verify your identification using the information we currently have on file, we may require that you supply additional information for the purposes of authenticating your identity as well as security or fraud protection. We will erase any further information you submit after we have completed verifying you.

Other privacy rights

• You have the right to object to the processing of your personal information.
• If your personal data is erroneous or no longer relevant, you may request that it be corrected or that its processing be restricted.
• You can appoint an authorised agent to make a CCPA request on your behalf. We may decline a request from an authorised agent who fails to provide documentation that they are legally authorised to act on your behalf under the CCPA.
• You may request that your personal information not be sold or shared with third parties in the future. When we receive an opt-out request, we will respond as quickly as feasible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, please contact us through email at info@thmfinity.com or by using the contact information listed at the bottom of this page. We’d want to hear from you if you have a problem about how we manage your data.

13. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as needed to ensure compliance with applicable laws.

This privacy policy may be updated from time to time. The revised version will be denoted by a new “Revised” date, and it will be effective as soon as it is available. We may notify you of major changes to this privacy policy by publicly displaying a policy of such changes or by directly emailing you a communication. We urge you to check our privacy policy on a regular basis so that you are aware of how we secure your information.

14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have any questions or complaints concerning this policy, please contact us by email at info@themfinity.com or by mail at:

Mfinity

5214F Diamond Heights Blvd #3613 San Francisco, CA 94131

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You may have the right, depending on your country’s regulations, to seek access to, modify, or delete the personal information we collect from you. To seek a review, modification, or deletion of your personal information, please email us at info@themfinity.com.