Effective starting: May 22, 2018
This policy explains the what, how, and why of the information we collect when you visit this site or when you use our Services. It also explains the specific ways we use and disclose that information. We take your privacy extremely seriously, and we never sell any information.
- We take End Users privacy extremely seriously
- We never sell any information
- Customer data - any information about customers of MNA are shared with some third parties that help us to provide better customer experience within MNA's service (e.g. our email service provider, store-front system, etc.)
- Communications between this MNA site and third-party products we use are all encrypted via SSL
Information We Collect
Among the types of Personal Data that MNA collects, by itself or through third parties, there are:
- Usage Data
- First name
- Last name
- Phone number
- Email address
- Various types of Data
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this MNA website.
Unless specified otherwise, all Data requested by MNA is mandatory and failure to provide this Data may make it impossible for MNA to provide its services. In cases where MNA specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact us.
Users are responsible for any third-party Personal Data obtained, published or shared through MNA and confirm that they have the third party's consent to provide the Data.
Mode and place of processing the Data
Methods of processing
MNA takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to MNA, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of MNA (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by MNA. The updated list of these parties may be requested from MNA at any time.
Legal basis of processing
MNA may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations MNA may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to data protection laws that apply to MNA;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which MNA is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in MNA;
- processing is necessary for the purposes of the legitimate interests pursued by MNA or by a third party.
In any case, MNA will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at MNA's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to another country or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by MNA to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with MNA using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between MNA and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of MNA’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by MNA within the relevant sections of this document or by contacting MNA.
MNA may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, MNA may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow MNA to provide its Services, as well as for the following purposes: Analytics, Contacting the User, Content commenting, Handling payments, Displaying content from external platforms, Infrastructure monitoring, Interaction with support and feedback platforms, Managing contacts and sending messages, Managing support and contact requests, Social features, Remarketing and behavioral targeting, Tag Management and Data transfer outside the EU.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
The rights of Users
Users may exercise certain rights regarding their Data processed by MNA.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by MNA, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, MNA will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from MNA.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in MNA or for the purposes of the legitimate interests pursued by MNA, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether MNA is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to MNA through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by MNA as early as possible and always within one month.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
- Google Analytics (Google Inc.)
- Facebook Ads conversion tracking (Facebook, Inc.)
- Google AdWords conversion tracking (Google Inc.)
- Twitter Ads conversion tracking (Twitter, Inc.)
Managing contacts and sending messages
- OmniSend (Soundest Limited, LLC.)
- Privy (Privy, Inc)
- Shopify (Shopify, Inc and its affiliates)
Managing support and contact requests
- Zoho Mail and CRM (Zoho Corporation)
Remarketing and behavioral targeting
- Facebook Custom Audience (Facebook, Inc.)
- Facebook Remarketing (Facebook, Inc.)
- AdWords Remarketing (Google Inc.)
- Twitter Remarketing (Twitter, Inc.)
- Twitter Tailored Audiences (Twitter, Inc.)
- Google Tag Manager (Google LLC)
- Inviting and suggesting friends (MNA)
- Public profile (MNA)
Further information about Personal Data
Analysis and predictions based on the User’s Data (“profiling”)
MNA may use the Personal and Usage Data collected through MNA to create or update User profiles. This type of Data processing allows MNA to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
Selling services online
The Personal Data collected are used to provide the User with services, including payment and possible delivery.
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. MNA may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. MNA adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and MNA, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:
- to enable or otherwise improve the decision-making process;
- to grant Users fair and unbiased treatment based on consistent and uniform criteria;
- to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
- to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within MNA, Users can check the relevant sections in this document.
Consequences of automated decision-making processes for Users and rights of Users subjected to it
As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:
- obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
- challenge a decision by asking MNA to reconsider it or take a new decision on a different basis;
- request and obtain from MNA human intervention on such processing. To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.
Chase might also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
Chase (JPMorgan Chase Bank, N.A. and its affiliates) - Orbital is a payment service provided by Chase.
Additional information about Data collection and processing
The User's Personal Data may be used for legal purposes by MNA in Court or in the stages leading to possible legal action arising from improper use of MNA or the related Services.
The User declares to be aware that MNA may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
System logs and maintenance
For operation and maintenance purposes, MNA and any third-party services may collect files that record interaction with MNA (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from MNA at any time. Please see the contact information at the end of this document.
How “Do Not Track” requests are handled
MNA does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, MNA shall collect new consent from the User, where required.
No Children Under Age of Minority
Users declare themselves to be adult according to their applicable legislation. Minors may use MNA only with the assistance of a parent or guardian. Under no circumstance persons under the age of majority in their local jurisdiction may use MNA.
MNA is allowed to transfer Personal Data collected within the USA to third countries (i.e. any other country not restricted by US sanctions) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Data transfer abroad based on consent (MNA)
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, MNA shall inform Users appropriately and collect their explicit consent via MNA.
Data transfer abroad based on standard contractual clauses (MNA)
If this is the legal basis, the transfer of Personal Data from the USA to third countries is carried out by MNA according to “standard contractual clauses” provided by the authority governing the third country.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by data protection legislation. For further information, Users are requested to contact MNA through the contact details provided in the present document.
Other legal basis for Data transfer abroad (MNA)
If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions is met:
- the transfer is necessary for the performance of a contract between the User and MNA or of pre-contractual measures taken at the User’s request;
- the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between MNA and another natural or legal person;
- the transfer is necessary for important reasons of public interest;
- the transfer is necessary for establishment, exercise or defence of legal claims;
- the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent. In such cases, MNA shall inform the User about the legal bases the transfer is based on via MNA.
Users can inquire with MNA to learn which legal basis applies to which specific service.
“Personal Data (or Data)” means any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
“Usage Data means” information collected automatically through MNA (or third-party services employed in MNA), which can include: the IP addresses or domain names of the computers utilized by the Users who use MNA, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
“User” means the individual using MNA who, unless otherwise specified, coincides with the Data Subject.
“Data Subject” means the natural person to whom the Personal Data refers.
“Data Controller (or Owner)” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of MNA. The Data Controller, unless otherwise specified, is the owner of MNA.
“MNA (or this Application)” means the means by which the Personal Data of the User is collected and processed.
“Service” means a service provided by MNA as described in the relative terms (if available) and on this site/application.
“European Union (or EU)” means all references made within this document to the European Union include all current member states to the European Union and the European Economic Area, unless otherwise specified.
“Cookies” means a small piece of data stored in the User's device.