Privacy & Terms of Use.

How MGV interacts with your data

Introduction

This privacy notice (the “Privacy Notice”) describes what, how and why MiddleGame Ventures S.A. together with its affiliates and funds collect, use, store, share and transfer personal data and information (“Personal Data”) about you, and what we do with that information.

MiddleGame Ventures S.A. is committed to protecting your personal data and respecting your privacy. We may collect, process and retain personal information when we interact with you, whether you are a visitor to our website or corresponding with us via email, telephone or otherwise (video conferencing). All data that we may collect and process from time to time will be collected and processed in accordance with all applicable laws, including without limitation, the General Data Protection Regulation (the “GDPR“) and any related legislation arising therefrom (“Applicable Laws“) and for the purposes defined below.

We have controls in place designed to ensure that the Personal Data we collect and process is relevant, accurate and appropriate for the purposes it is used.

 

Terminology

Personal Data: any information relating to an identified or identifiable natural person.

Data Subject: a living individual to whom Personal Data relates.

Data Controller: the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of Personal Data.

MiddleGame Ventures S.A. acts as a Data Controller of your Personal Data.

 

Types of personal data that MiddleGame Ventures S.A. may collect and process

  • Identification Data. Includes first name, maiden name, last name, username or similar identifier, passport/ID card data, and tax identification numbers.
  • Administrative Data. Includes marital status, title, date of birth, and gender.
  • Contact Data. Including billing address, correspondence address, email address, and telephone numbers.
  • Professional Data. Includes job/occupation, employer, positions and mandates held, and employment and education history.
  • Financial Data. includes bank account details and bank statements and financial transaction data.
  • Marketing and Communications Data. Includes any preferences in receiving marketing from us.
  • Technical Data. Includes internet protocol (IP) address and log-in data (where applicable).

 

How we collect Personal Data

We may collect Personal Data through direct interactions, automatic technologies or interactions and/or from third parties or publicly available sources, including without limitation through:

  • MiddleGame Ventures S.A.’s website.
  • Email, telephone and other communications in the course of our business relationship with you.

For what purposes we collect Personal Data

Sharing of Personal Data with third parties

If you are contacting us on behalf of a company, or if you intend to engage with us in any other business transaction, we may need to transfer your Personal Data to a third party for processing where this is required in connection with the purpose for which it was collected. We may be legally, contractually or otherwise obligated to share your Personal Data with (a) professional advisers, including transfer agents, consultants, lawyers, accountants, bankers and auditors, (b) regulators and government bodies, (c) IT service providers, (d) any other third-party service where the transfer of information is required in connection with the purpose for which it was collected.

 

International transfers of Personal Data

Although MiddleGame Ventures S.A. is located in Luxembourg, it is an international business. In the processing of Personal Data, we may therefore be required to transfer Personal Data to a party that is not bound by European legislation, including the GDPR. Where this is the case, we will ensure your information is adequately protected and safeguarded by contractual, technical and organizational means.

 

Retention of Personal Data

We will only retain your Personal Data for as long as necessary to achieve the purpose for which it was collected. We will retain the Personal Data for the purpose of satisfying our legitimate interests, as well as any legal, regulatory, reporting and accounting requirements associated with our business and other dealings relating to Personal Data. While retaining your Personal Data, we will ensure that it is secure from unauthorized use or disclosure. Once your Personal Data is no longer required for the purposes for which it was acquired, it will be securely destroyed in accordance with applicable laws and regulations.

 

Your rights concerning your personal data

If the processing of your Personal Data is within the scope of the GDPR you have certain rights that you can exercise in connection with your Personal Data: These are the rights to:

  • Request access to your Personal Data through a data subject assess request. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request rectification of your Personal Data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with applicable law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your Personal Data to you or to a third party. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

​This Privacy Notice acts as a primary safeguard to inform you of your data rights. If we require additional Personal Data that is not outlined in this Privacy Notice, we will supply you with a supplementary privacy notice that will outline the use and purpose of such additional collection of Personal Data.

 

Cookies

MiddleGame Ventures S.A. may use cookies (which are small amounts of data sent from a web server to your browser that are stored on your computer’s hard drive) to keep track of your use of the Internet Services, to remember your preferences, to meet your interests, and to improve the quality of the Internet Services.

Generally, you can set your browser not to accept cookies or to notify you if you are sent a cookie, giving you the opportunity to choose whether or not to accept the cookie. Please note that if you do set your browser not to accept cookies, certain Internet Services may not function properly.

 

Security

MiddleGame Ventures S.A. has implemented measures to help protect Personal Data from loss, misuse or unauthorized access or disclosure. While we strive to protect Personal Data, we cannot guarantee its security.

If you believe you have found a vulnerability or security concern with our website, please submit a report to [email protected] 

Please include the type of issue, the URL, a proof of concept, and the detailed steps required to reproduce the issue. We take all disclosures very seriously.

 

Links

The MiddleGame Ventures S.A.’s website may contain links to other websites. We are not responsible for the privacy practices of any such other website (whether accessed through an advertisement, service or content link) and urge you to review such practices prior to submitting any information or Personal Data to such websites.

 

Changes

This Privacy Notice aims to be accurate and clearly reflective of our current practices with respect to how we process your Personal Data. If any changes to our website or changes to legislation require a change to our Privacy Notice, we will make these changes clearly visible on our website. Please do check this Privacy Notice often to confirm any changes. Additionally, if the information that you have previously submitted to us is no longer accurate, it remains your responsibility to notify us of any changes to our recorded information.

 

Contact

If you require any additional details or information or would like to exercise any of your data privacy rights, please contact us using the following contact details: [email protected]

In case an Individual wants to formulate a complaint in terms of the data processing under this Privacy Policy, such complaint should also be addressed to the above contact details.

Should the Controller not be able to resolve such complaint and in any event, the Data Subject may address a complaint to the supervisory authority, the Commission Nationale pour la Protection des Données (“CNPD”), either online or by using the contact details below:

CNPD