MIO Privacy Policy, Cookie Policy and Website Notice

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

This Policy 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.

MIO is the controller 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 no. 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 Ms. Lisa Chun under Lisa_Chun@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 Policy.

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

What we collect

We may collect the following personal information 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
  • And 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 other types of anonymous 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 and use 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 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.

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 information 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. 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);
  • 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 information about you to non-affiliated third parties, unless it is 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 information with any third parties except as required by law.

We may share your personal data collected via our website without further disclosure 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.

How we use cookies on our website

We use cookies and similar techniques on our website for different purposes as set out below. By adapting your browser settings you can either prohibit the setting of such cookies or delete cookies already placed. However, this may lead to an impaired usability of our website.

A cookie is a small file which is placed on your computer's hard drive.  

Certain cookies are mandatory for the operation of our website, e.g. to enable us to display the website in the most favorable fashion or to remember your recent choices (e.g. language, web browser, screen resolution, etc.) or to remember your cookie choices. 

Other cookies are not mandatory but may help us to better understand the use of our website by analyzing the actions of our website users in aggregated format or to track campaigns from banner advertisements and opt-in emails.  We may use third-party providers to help us determine which of our advertisements are most likely to be of interest to you.  These providers may use behavioral information, such as how you navigate the internet, to provide relevant advertisements to you.

We also allow some of these companies to use tracking pixels.  Tracking pixels may be used to collect and store information about visits to our website, such as which pages you viewed and how long you spent on the website, as well as the specific advertisement that you clicked to visit our site.  No personally identifiable information is stored on these cookies or web pixels.  The information reported to us is aggregated and anonymous. We use this information to understand, for example, the effectiveness of our advertising and marketing.

These non-mandatory cookies require your express consent. We will ask you to provide your consent upon your first visit on our website and will provide you with more detailed information regarding each cookie in this context. You can at any time opt out from these cookies by changing your cookie preferences.

Analytics Services

Upon your express consent, our website uses the analytics service of Google Analytics which is operated by Google Ireland Ltd. For this purpose Google stores cookies on your device and which enable to track and analyze your use of the website and collects certain information, e.g. your IP address and what sites have been visited by you. This information is transferred to Google in the US but all identifiable information (namely your IP address) is truncated before transfer to the US so that it cannot serve to identify you. Hence, no personal data in the meaning of the GDPR will be transferred to the US. Should nonetheless certain information be transferred to the US which may enable to identify you, we will ensure that adequate measures in compliance with GDPR are met for an adequate level of data protection. You can request further information about these measures by contacting us. Google is obliged not to match this data with data from other sources and will process the data on our behalf in order to provide us anonymized and aggregated usage schemes of our website. 

You can also install a browser plugin provided by Google in order to stop tracking by Google Analytics here: google.com/dlpage/gaoptout?hl=de

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 Policy.  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 from 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;
  • In case 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;
  • The right to lodge a complaint with a competent supervisory authority, e.g. at the place of your residence.