Privacy Notice

Please select the applicable Privacy Notice based on where you are located:

For Customers in the United States: MIO Partners, Inc. U.S. Privacy Notice for Customers
For Customers in the European Economic Area or the United Kingdom: MIO European Data Protection Notice


 

For Customers in the United States: MIO Partners, Inc. U.S. Privacy Notice for Customers

October 2021

MIO Partners, Inc. (“MIO” or “we”) recognize and respect the privacy expectations of our customers, and we are committed to safeguarding our customers’ nonpublic personal information. MIO is providing this notice to you so that you will know what types of information we collect about individuals who apply for or obtain our products or services, how we handle and protect such information, and the circumstances in which that information will be disclosed to third parties who are not affiliated with us. The provisions of this notice apply to former customers as well as current customers.

As used in this Notice, “nonpublic personal information” is nonpublic information about you that we obtain in connection with providing you with a financial product or service for your personal, family, or household purposes.

Information we collect

We collect nonpublic personal information about you for business purposes in connection with our investment management operations. Such information is collected from the following sources:

  • Subscription Documents, Account Opening Documents and Other Forms, which may include information such as your name, address, Social Security number, income information, net worth, investment experience, educational background and banking information;
  • Account History, such as information regarding the assets in your account and your account’s transactions, including the parties to a transaction, the positions held or sold, and pricing; and
  • Correspondence, including written, telephonic or electronic between you, us and/or any service providers for your account.
Information disclosure to third parties

We do not disclose any nonpublic personal information about you to non-affiliated third parties, unless such disclosure is (i) permitted or required by law, (ii) at your direction, or (iii) necessary to provide you with services.  We do not sell any personal information about you to any third party.

In the normal course of business, all of the nonpublic personal information we collect about you, as described above, may be shared with other persons who provide services in connection with your account (including brokers, administrators, custodians, accountants or attorneys, as well as any other service providers for your account).

We may also disclose personal information with non-affiliated entities and regulatory authorities as permitted by applicable law.  For example, we may disclose such information to cooperate with regulatory authorities and law enforcement agencies and as necessary to protect our rights and property.

Protecting confidentiality and security

We maintain physical, electronic, and procedural safeguards to protect the nonpublic personal information we have about you.  We treat this information in a confidential manner. We restrict access to nonpublic information about you to employees who have an appropriate reason to access it, such as to administer your account or offer our products and services.  We educate our employees on the importance of protecting the privacy and security of confidential personal information.  In addition, we require third parties with whom we share information to:

  • maintain policies and procedures designed to assure only appropriate access to, and use of information about, our customers; and
  • maintain physical, electronic and procedural safeguards that comply with federal standards to guard nonpublic information of our customers.

1. For purposes of this notice, the terms “customer” or “customers” includes both past and present customers of ours and individuals who have provided us with nonpublic personal information but have not become our customers.


 

For Customers in the European Economic Area or the United Kingdom: MIO European Data Protection Notice

Last Revised: 29 October 2021

This MIO Data Protection Notice (hereinafter referred to as the “Notice”) applies to you if you are a natural person in a member state of the European Economic Area or the United Kingdom.

This Notice sets out how MIO Partners, Inc. (as the entity hosting our website), MIO Partners (EU) Limited and MIO-Partners (EU) GmbH (each, as the case may be, “we” or “MIO”) use and protect any information that you give when you contract with us or use our website. Our Website Cookie Notice is incorporated by reference. This Notice also explains your rights with respect to our processing of your Personal Data and other options we may provide to you. This Notice may be supplemented by additional privacy notices that are provided when Personal Data is collected from you. In this Notice, when we talk about “Personal Data,” we mean any information that relates to an identifiable person.

The MIO entities listed above are joint controllers with regard to any Personal Data collected in connection with an agreement with you or your use of our website in accordance with Art. 4(7) of the EU General Data Protection Regulation 2016/679 (hereinafter referred to as the “GDPR”).

You can contact us at any time as follows:

MIO Partners, Inc:

by mail to: 245 Park Avenue, 13th Floor, New York, NY 10167, United States
by email to: MIO_Partners@miopartners.com
by phone under: +1(212) 203-4000

MIO Partners (EU) Limited:

by mail to: 70 Pall Mall London SW1Y 5ES United Kingdom
by email to: MIO_Partners@miopartners.com
by phone under: +44-20-7961-5957

MIO-Partners (EU) GmbH:

by mail to: Ludwigstr. 8, 80539 Munich, Germany 
by email to: MIO_Partners@miopartners.com
by phone under: +49 (0)89 5594 3308   

You can also directly contact our Global Data Protection Officer Mr. Bastien Claereboudt at Bastien_Claereboudt@miopartners.com

MIO is committed to ensuring that your privacy is protected. Information that is requested of you will only be used in accordance with this Notice.

MIO may change this Notice from time to time by updating this document.

What we collect

We may collect the following Personal Data when you enter into an agreement with us:

  • Name and tax identification number

  • Contact information including email address
  • Financial information concerning your investments
  • Financial institution account numbers and payment related information
  • Educational background
  • Age, investable assets and risk tolerance
  • Knowledge and experience in investments
  • Demographic information such as postcode, preferences and interests
  • Any other information requested by us that may be needed to perform your investment.

(hereinafter collectively referred to as the “Contract Data”).

When you enter our website, we may collect the following information:

  • Server log information and similar information when you visit our website and use its services, including browser information and information collected through the use of cookies and pixel tags.

(hereinafter collectively referred to as the “Website Data”).

What we do with the information we gather

We will process the Contract Data solely to the extent this is required to perform under the contractual arrangement with you in accordance with Art. 6(1)(b) GDPR (i.e., processing that is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract) and to comply with our legal obligations, e.g. accounting and recording obligations under commercial and tax law or cooperation and disclosure obligations towards competent supervisory authorities in accordance with Art. 6(1)(c) GDPR (i.e., processing that is necessary for compliance with a legal obligation to which the controller is subject).

We may periodically send promotional materials about new products or other information which we think you may find interesting using the email address which you have provided. We may also use your Personal Data to send you promotional information about third parties which we think you may find interesting if you have consented to receiving such information in accordance with Art. 6(1)(a) GDPR (i.e., where the data subject has given consent to the processing of his or her personal data for one or more specific purposes). You may at any time opt out from receiving such information, either by email to MIO_Partners@miopartners.com or by opting out by following the procedure contained in each promotional email. 

We use the Website Data in particular for the following purposes:
  • to provide the content on our website to you (Art. 6(1)(f) GDPR) (i.e., processing that is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data);
  • to analyze the use and improve our website accordingly (Art. 6(1)(f) GDPR);
  • to customize our website according to your interests (Art. 6(1)((f) GDPR).

We may share the above data with our affiliated companies to the extent this is required for the above purposes (e.g. if the Contract Data is received by a different affiliated company than the one that is supposed to provide a service). 

We do not disclose any Personal Data about you to non-affiliated third parties, unless it is expressly permitted or required by law (e.g. to regulatory authorities), at the direction of you, or is necessary to provide services.  We do not sell, rent, or trade your Personal Data with any third parties except as required by law.

We may share your Personal Data collected via our website without further notice to you if we hire other companies to perform certain business and technology related functions (e.g. mailing information, database maintenance, transfer agent and payment processing, or subscription and redemption processing).  In such a case, we only provide them with the minimum information they need to perform their specific function and will contractually ensure that they use the data solely for the purpose of providing their services to us.
Should any recipient of Personal Data not be located in a member state of the European Economic Area (EEA) and thus be subject to a different data protection regime, we will ensure by adequate measures in compliance with applicable laws that such recipient maintains an adequate level of data protection when processing your Personal Data. We are happy to provide any details on these measures upon request using the above communication channels.

Data Retention

Generally, we retain your Personal Data as long as it is required for the above purposes. For Contract Data this is usually after the contractual relationship with you has been terminated and all applicable statutory retention periods have expired. For Website Data this is usually the case after you have left our website and closed your browser.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Links to other websites

Our website may contain links to other websites of interest.  However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Notice.  You should exercise caution and look at the privacy statement applicable to the website in question.]

Your data protection rights

You have the following statutory rights with regard to your Personal Data processed by us:

  • The right to request information whether we process your data and to access this data in accordance with Art. 15 GDPR;
  • The right to correct or complete incorrect or incomplete data about you in accordance with Art. 16 GDPR;
  • The right to request deletion of your data in accordance with Art. 17 GDPR;
  • The right to request restriction of processing in accordance with Art. 18 GDPR;
  • The right to object to processing we conduct based on legitimate interests (Art. 6(1)(f) GDPR) due to grounds relating to your particular situation or processing for marketing purposes in accordance with Art. 21 GDPR;
  • The right to have your data transferred to you or a third party in accordance with Art. 20 GDPR;
  • Where we process your data on the basis of consent (Art. 6(1)(a) GDPR), you have the right to revoke such consent at any time without cause with effect from the revocation onward but not affecting any processing conducted prior to revocation; and
  • The right to lodge a complaint with a competent supervisory authority, e.g. at the place of your residence.