4MGI is a boutique consultancy and custom software development (the
"Service") offered from time to time via www.4mgi.com (the “Site”).
The Service is owned and operated by 4MGI LLC (“Company”, “we” or “us”).
PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE
COMPANY SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE
TO BE BOUND BY ALL THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS OF
SERVICE. IF YOU DO NOT AGREE TO SUCH TERMS, EXIT THIS PAGE AND DO NOT
ACCESS OR USE THE COMPANY SERVICE.
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INTRODUCTION
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The Company is committed to safeguarding the privacy of our website
and service users (“users,” or “you”).
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This policy applies where we are acting as a data controller with
respect to your personal data, in other words, where we determine
the purposes and means of the processing of that personal data.
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Terms of Service. Use of the Company Service is subject to the terms
of our Terms of Service which is hereby incorporated and made part
of this Privacy Policy. By using the Company Service, you agree to
be bound by our Terms of Service.
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Your use of the Company Service is subject to the terms and
conditions set forth in this Privacy Policy (the “Privacy Policy”).
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We continually strive to find new ways to enhance your experience
with the Company Service and we may modify this Privacy Policy from
time to time to reflect changes in our privacy practices. You are
encouraged to review this Privacy Policy periodically and to check
the “Last Updated” date at the top of the Privacy Policy for the
most recent version. If we make changes to this Privacy Policy, we
will notify you here, by email, or by means of notice through the
Website, the Application, or any other part of the Company Service.
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HOW WE USE YOUR PERSONAL DATA
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In this Section 2 we have set out:
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The general categories of personal data that we may process;
- The purposes for which we may process personal data; and
- The legal bases of the processing.
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Types and Uses of Collected Information. Company collects two types
of information about you, “Personally Identifiable Information” and
“Non-Personally Identifiable Information”.
Personally Identifiable Information
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IPersonally identifiable information is information that identifies
a specific person. When you engage in certain activities via the
Company Service, including but not limited to creating an account,
sending feedback, or otherwise participating in the Company Service
(collectively, “Identification Activities”), we may ask you to
provide certain information about yourself. If you elect to engage
in an Identification Activity, we may ask you to provide us with
certain personal information about yourself, such as your name,
address, email address, telephone number and/or any other
information you provide to us, to create your account of profile,
send communications about them to you, and populate forms for future
transactions.
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If you enroll in the Company Service through a third party (such
as Facebook or Google) then Company may receive Personally
Identifiable Information from such third party and by using the
Company Service, you consent to such receipt of Personally
Identifiable Information and its use pursuant to this Privacy
Policy by Company.
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We may use or share Personally Identifiable Information to
provide products and/or services to you, to enable Third-Party
advertisers to provide products and/or services to you, enhance
the operation of the Company Service, improve our marketing and
promotional efforts, analyze use of the Company Service, and
tailor your experience with third parties as provided below in
this Privacy Policy. We may also use Personally Identifiable
Information to troubleshoot, resolve disputes, accomplish
administrative tasks, contact you, enforce our agreements with
you, including our Terms of Service and this Privacy Policy,
comply with applicable law, and cooperate with law enforcement
activities.
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We may process data about your use of our website and services
("usage data"). The usage data may include your IP address,
geographical location, browser type and version, operating
system, referral source, length of visit, page views and website
navigation paths, as well as information about the timing,
frequency and pattern of your service use. The source of the
usage data is our analytics tracking system. This usage data may
be processed for the purposes of analyzing the use of the
website and services. The legal basis for this processing is
your consent or our legitimate interests, namely monitoring and
improving our website and services.
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We may process your account data ("account data"). The account
data may include your name and email address. The source of the
account data is you. The account data may be processed for the
purposes of operating our website, providing our services,
ensuring the security of our website and services, maintaining
back-ups of our databases and communicating with you. The legal
basis for this processing is your consent or our legitimate
interests, namely monitoring and improving our website and
services.
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We may process your information included in your personal
profile on our website ("profile data"). The profile data may
include your name, address, telephone number, email address,
profile pictures, and company name. The profile data may be
processed for the purposes of enabling and monitoring your use
of our website and services. The legal basis for this processing
is your consent or our legitimate interests, namely monitoring
and improving our website and services.
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We may process information that you post for publication on our
website or through our services ("publication data"). The
publication data may be processed for the purposes of enabling
such publication and administering our website and services. The
legal basis for this processing is your consent or our
legitimate interests, namely monitoring and improving our
website and services.
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We may process information contained in any inquiry you submit
to us regarding goods and/or services ("inquiry data"). The
enquiry data may be processed for the purposes of offering,
marketing and selling relevant goods and/or services to you. The
legal basis for this processing is your consent or our
egitimate interests, namely monitoring and improving our
website and services.
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We may process information relating to transactions, including
purchases of goods and services, that you enter into with us
and/or through our website ("transaction data"). The transaction
data may include first and last names, an email address to be
used as a login, billing contact information, credit card number
and a password. The transaction data may be processed for the
purpose of supplying the purchased goods and services and
keeping proper records of those transactions. The legal basis
for this processing is the performance of a contract between you
and us and/or taking steps, at your request, to enter into such
a contract and our legitimate interests.
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We may process information that you provide to us for the
purpose of subscribing to our email notifications and/or
newsletters ("notification data"). The notification data may be
processed for the purposes of sending you the relevant
notifications and/or newsletters. The legal basis for this
processing is your consent or our legitimate interests, namely
monitoring and improving our website and services.
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We may process information contained in or relating to any
communication that you send to us ("correspondence data"). The
correspondence data may include the communication content and
metadata associated with the communication. Our website will
generate the metadata associated with communications made using
the website contact forms. The correspondence data may be
processed for the purposes of communicating with you and
record-keeping. The legal basis for this processing is your
consent or our legitimate interests, namely monitoring and
improving our website and services.
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We may process any of your personal data identified in this
policy where necessary for the establishment, exercise or
defense of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure. The legal basis for
this processing is our legitimate interests, namely the
protection and assertion of our legal rights, your legal rights
and the legal rights of others.
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In addition to the specific purposes for which we may process
your personal data set out in this Section 2, we may also
process any of your personal data where such processing is
necessary for compliance with a legal obligation to which we are
subject, or in order to protect your vital interests or the
vital interests of another natural person.
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Please do not supply any other person's personal data to us
unless we prompt you to do so and you have that person’s
authorization to provide such.
Non-Personally Identifiable Information
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Non-Personally Identifiable Information is information that does not
identify a specific person. This type of information may include
things like the Uniform Resource Locator (“URL”) of the website you
visited before coming to the Company Service or otherwise
participating in the Company Service, the URL of the website you
visit after leaving the Company Service, the type of browser you are
using, your Internet Protocol (“IP”) address, mobile carrier
information, mobile device information, or general and/or aggregated
location data that does constitute Personally Identifiable
Information. We, and/or our authorized Third-Party Service
Providers, may automatically collect this information when you visit
or use the Company Service using electronic tools like Cookies and
Web beacons or Pixel tags, as described below in this Privacy
Policy. We use Non-Personally Identifiable Information to
troubleshoot, administer the Company Service, analyze trends, gather
demographic information, comply with applicable law, and cooperate
with law enforcement activities. We may also share this information
with our authorized Third-Party Service Providers to measure the
overall effectiveness of our products and services.
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PROVIDING YOUR PERSONAL DATA TO OTHERS.
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We do not rent or sell your personally identifiable information to
third parties.
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We may disclose your personal data to any member of our group of
companies, this means our subsidiaries, our ultimate holding company
and all its subsidiaries insofar as reasonably necessary for the
purposes, and on the legal bases, set out in this policy.
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Financial transactions relating to our website and services may be
handled by our payment services providers. We will share transaction
data with our payment services providers only to the extent
necessary for the purposes of processing your payments, refunding
such payments and dealing with complaints and queries relating to
such payments and refunds.
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We may disclose your inquiry data to one or more of those selected
third-party suppliers of services via APIs identified on our website
for the purpose of enabling them to connect your account with their
Services, if any. Each such third party will act as a data
controller in relation to the inquiry data that we supply to it.
Each such third party will supply to you a copy of its own privacy
policy, which will govern that third party's use of your personal
data.
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Company has an obligation when providing any and all of your data to
any third party is to ensure that the third party effectively
processes the personal data in a manner consistent with our own
policies. In the event of a compliance failure by such third-party
Company may be liable for the third-party lack of compliance and
shall take appropriate steps to remedy the situation including, but
not limited to, ensuring that processing by the third party shall
cease and taking steps to remediate unauthorized processing.
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In addition to the specific disclosures of personal data set out in
this Section 3, we may disclose your personal data where such
disclosure is necessary for compliance with a legal obligation to
which we are subject, or in order to protect your vital interests or
the vital interests of another natural person. We may also disclose
your personal data where such disclosure is necessary for the
establishment, exercise or defense of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
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We do disclose personal information in response to lawful requests
by public authorities, including to meet national security or law
enforcement requirements. We'll notify you when we're asked to hand
over your personal information in this way unless we're legally
prohibited from doing so. When we receive requests like this, we'll
only release your personal information if we have a good faith
belief that the law requires us to do so.
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ABOUT COOKIES.
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A cookie is a file containing an identifier (a string of letters and
numbers) that is sent by a web server to a web browser and is stored
by the browser. The identifier is then sent back to the server each
time the browser requests a page from the server.
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Cookies may be either "persistent" cookies or "session" cookies: a
persistent cookie will be stored by a web browser and will remain
valid until its set expiry date, unless deleted by the user before
the expiry date; a session cookie, on the other hand, will expire at
the end of the user session.
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Cookies do not typically contain any information that personally
identifies a user, but personal information that we store about you
may be linked to the information stored in and obtained from
cookies.
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COOKIES THAT WE USE.
We use cookies for the following purposes:
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Authentication - we use cookies to identify you when you visit our
website and as you navigate our website.
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Security - we use cookies as an element of the security measures
used to protect user accounts, including preventing fraudulent use
of login credentials, and to protect our website and services
generally.
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Analysis - we use cookies to help us to analyze the use and
performance of our website and services; and
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COOKIES USED BY OUR SERVICE PROVIDERS.
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Our service providers use cookies and those cookies may be stored on
your computer when you visit our website.
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We use Google Analytics to analyze the use of our website. Google
Analytics gathers information about website use by means of cookies.
The information gathered relating to our website is used to create
reports about the use of our website. Google's privacy policy is
available at:
https://www.google.com/policies/privacy/.
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MANAGING COOKIES.
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Most browsers allow you to refuse to accept cookies and to delete
cookies. The methods for doing so vary from browser to browser, and
from version to version. You can however obtain up-to-date
information about blocking and deleting cookies via these links:
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https://support.google.com/chrome/answer/95647?hl=en
(Chrome);
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https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
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http://www.opera.com/help/tutorials/security/cookies/
(Internet Explorer);
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https://support.apple.com/kb/PH21411
(Safari); and
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https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Safari); and
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Blocking all cookies will have a negative impact upon the usability
of many websites.
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If you block cookies, you will not be able to use all the features
on our website.
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ANALYTICS.
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We continuously improve our websites and our products, and we
utilize different third-party web analytics tools to help us do so.
We are interested in how visitors use our websites, our desktop
tools, our mobile applications, what they like and dislike, and
where they haveproblems. Our products, desktop tools and mobile
applications use analytical tools tounderstand feature usage
patterns, to enhance and improve your product experience and offer
you specific usage tips and guidance. In connection with normal
business operations, as well as to increase functionality and
enhance your user experience, this usage information may be linked
to personal information that we have about individual users. We
maintain ownership of this data and we do not share this type of
data about individual users with third parties.
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Our mobile applications will also use analytical tools to help
gather non-personally identifiable data about download and
application usage. We may use information such as IP addresses to
determine the general geographic locations areas of our visitors,
but this information is not correlated to personal information about
individual users. The web beacons used in conjunction with these
tools may gather data such as what browser a person uses, what
operating systems are used, domain names, MIME types, what is
downloaded, and what content, products and services are reviewed
when visiting or registering for services at one of our websites or
using one of our mobile applications.
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This information is used solely to assist us in maintaining a more
effective and useful websites and products for our customers. This
data will not be shared with third parties without your prior
consent or unless required by law.
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YOUR RIGHTS.
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In this Section 9, we have summarized the rights that you have under
data protection law. Some of the rights are complex, and not all of
the details have been included in our summaries. Accordingly, you
should read the relevant laws and guidance from the regulatory
authorities for a full explanation of these rights.
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Your principal rights under data protection law are:
- The right to access;
- The right to restrict processing;
- The right to object to processing;
- The right to withdraw consent.
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You have the right to confirmation as to whether or not we process
your personal data and, where we do, access to the personal data,
together with certain additional information. That additional
information includes details of the purposes of the processing, the
categories of personal data concerned and the recipients of the
personal data. Providing the rights and freedoms of others are not
affected, we will supply to you a copy of your personal data. The
first copy will be provided free of charge, but additional copies
may be subject to a reasonable fee.
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In some circumstances you have the right to the erasure of your
personal data without undue delay. Those circumstances include: the
personal data are no longer necessary in relation to the purposes
for which they were collected or otherwise processed; you withdraw
consent to consent-based processing; you object to the processing
under certain rules of applicable data protection law; the
processing is for direct marketing purposes; and the personal data
have been unlawfully process. However, there are exclusions of the
right to erasure. The general exclusions include where processing is
necessary: for exercising the right of freedom of expression and
information; for compliance with a legal obligation; or for the
establishment, exercise or defense of legal claims.
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In some circumstances you have the right to restrict the processing
of your personal data. Those circumstances are: you contest the
accuracy of the personal data; processing is unlawful but you oppose
erasure; we no longer need the personal data for the purposes of our
processing, but you require personal data for the establishment,
exercise or defense of legal claims; and you have objected to
processing, pending the verification of that objection. Where
processing has been restricted on this basis, we may continue to
store your personal data. However, we will only otherwise process
it: with your consent; for the establishment, exercise or defense of
legal claims; for the protection of the rights of another natural or
legal person; or for reasons of important public interest.
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You have the right to object to our processing of your personal data
on grounds relating to your particular situation, but only to the
extent that the legal basis for the processing is that the
processing is necessary for: the performance of a task carried out
in the public interest or in the exercise of any official authority
vested in us; or the purposes of the legitimate interests pursued by
us or by a third party. If you make such an objection, we will cease
to process the personal information unless we can demonstrate
compelling legitimate grounds for the processing which override your
interests, rights and freedoms, or the processing is for the
establishment, exercise or defense of legal claims.
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You have the right to object to our processing of your personal data
for direct marketing purposes (including profiling for direct
marketing purposes). If you make such an objection, we will cease to
process your personal data for this purpose.
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To the extent that the legal basis for our processing of your
personal data is:
- Consent; or
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That the processing is necessary for the performance of a
contract to which you are party or in order to take steps at
your request prior to entering into a contract, and such
processing is carried out by automated means, you have the right
to receive your personal data from us in a structured, commonly
used and machine-readable format. However, this right does not
apply where it would adversely affect the rights and freedoms of
others.
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To the extent that the legal basis for our processing of your
personal information is consent, you have the right to withdraw that
consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.
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Retaining and deleting personal data
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This Section 10 sets out our data retention policies and procedure,
which are designed to help ensure that we comply with our legal
obligations in relation to the retention and deletion of personal
data.
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Personal data that we process for any purpose or purposes shall be
kept until such time as we receive a request for deletion from you.
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Notwithstanding the other provisions of this Section 10, we may
retain your personal data where such retention is necessary for
compliance with a legal obligation to which we are subject, or in
order to protect your vital interests or the vital interests of
another natural person.
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WHO CAN I ASK IF I HAVE ADDITIONAL QUESTIONS?
For additional inquiries about the privacy of your information, you can contact Us by emailing us at: [email protected]