Privacy Notice & Cookie Policy

1. Introduction

MI & Associates expertise lies in the provision of concise and highly effective strategic business advisory services to clients, especially those that are focused on Emerging and Frontier Market geographic locations. We take the privacy and security of your personal information very seriously and will only use your personal information as set out in this Privacy Notice or as we may otherwise inform you from time to time. This policy explains how we use and protect the information given to us by users of our website.

2. Contact details

If you have any questions or comments regarding this privacy policy in relation to data protection and your rights, you can contact us by email mi@miandassociates.com or in writing to: MI & Associates 84 Brook Street Mayfair London W1K 5EH UK

3. The personal information we process

3.1. Depending on the nature of our relationship with you, we will collect various types of personal information about you which may include some or all of the following:

3.1.1. Your identification information (which may include your name, ID card and passport numbers, nationality, place and date of birth, gender, photograph and/or IP address and personal information relating to claims, court cases and convictions, politically exposed person (PEP) status, personal information available in the public domain and such other information as may be necessary for MI & Associates to provide its services and to complete its client due diligence process and discharge its AML/CFT/CPF obligations);

3.1.2. Your tax status information (which may include your tax residency, tax ID and tax status).

3.1.3. Your contact information (which may include postal residential and business addresses, personal and business e-mail address and your home, business and mobile telephone numbers).

3.1.4. Your family relationships (which may include your marital status, the identity of your spouse and the number of children that you have).

3.1.5. Your professional and employment information (which may include your level of education and professional qualifications, your employment, employer’s name and details of directorships and other offices which you may hold).

3.1.6. Financial information, sources of wealth and your assets (which may include details of your assets, sources of wealth, shareholdings and your beneficial interest in assets, your bank details and your credit history).

3.1.7. Transaction data including details about payments to and from you and other details of services you have obtained from us.

3.1.8. Profile data including usernames and passwords, details of services, your interests and preferences; and

3.1.9. IP Address (we may collect your IP (Internet Protocol) address to help diagnose problems with our server, and to administer our Site. An IP address is a number that is assigned to your computer when you use the Internet. This information does not contain any personally identifiable information about you. Your IP address is also used to help identify you during a particular session and to gather broad demographic data. We may also collect usage data including information about how you interact with and use our website and services and marketing and communications data including your preferences for receiving marketing communications from us and our third parties.

3.2. We may collect and process personal information regarding people connected to you, either by way of professional (or other) association or by way of family relationship.

3.3. We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

4. Where we obtain your personal information

4.1. We collect your personal information from the following sources:

4.1.1. personal information which you give to us, including but not limited to: (a) on such other forms and documents as we may request you complete or provide in relation to the administration/management of any of our services. (b) information gathered through client due diligence carried out as part of our compliance with regulatory requirements; or (c) any personal information provided by way of correspondence with us by phone, email or otherwise.

4.1.2. personal information we receive from third party sources, such as: (a) entities in which you or someone connected to you has an interest; (b) your legal and/or financial advisors; (c) other financial institutions who hold and process your personal information; (d) other publicly available sources such as UK Companies House; (e) credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements.

4.1.3. personal information received while dealing with advisors, regulators, official authorities, payment providers and service providers by whom you are employed or engaged or for whom you act.

5. Why we collect your personal information? Lawful grounds for processing:

5.1. Unless we inform you otherwise then we may hold and process your personal information on the following lawful grounds:

5.1.1. the processing is necessary to comply with our legal obligations including in any employment or social field.

5.1.2. the processing is necessary for our legitimate interests or the legitimate interests of a third party to whom your personal information is disclosed, provided your interests and fundamental rights do not override those interests.

5.1.3. the processing is necessary for the performance of a contract to which you are a party, or to take such steps, at your request, with a view to entering you into such a contract.

5.1.4. the processing is necessary in our performance of a public task or in the public interest.

5.1.5. the processing is necessary to exercise, bring or defend a legal claim or to prevent and detect an unlawful act; and

5.1.6. in exceptional circumstances, where we have obtained your consent to processing your personal information for a specific purpose. Purposes of processing:

5.2. Your personal information may be processed for the purposes set out below (“Purposes”). The Purposes based on our legitimate interests (and in some cases on other lawful bases as stated) are set out in paragraphs 5.2.1 to 5.2.4 inclusive: 5.2.1. facilitating the administration of our business, clients and/or our service providers.

5.2.2. communicating with you as necessary in connection with our services or in relation to a contract we have in place with you.

5.2.3. monitoring and recording, including of telephone and electronic communications, system use and transactions, for: (a) quality, business analysis, training and related purposes to improve service delivery and/or to monitor adherence to our internal staff policies and procedures; and (b) for the prevention, detection, investigation and prosecution of any unlawful act (or omission to act) or in the wider public interest.

5.2.4. disclosing your personal information to any bank or financial institution in providing our services.

5.2.5. to enforce or defend our legal and contractual rights or those of third-party service providers.

5.2.6. to comply with legal or regulatory obligations imposed on us.

5.2.7. collecting, processing, transferring and storing customer due diligence, source of funds information and verification data under applicable anti-money laundering and terrorist financing laws and regulations; and

5.2.8. liaising with or reporting to any regulatory authority (including tax authorities) with whom we are either required to co-operate or report to, or with whom we decide or deem it is appropriate to co-operate.

5.3. You may receive marketing communications if you have opted in to receive them and have not opted out of receiving the marketing.

5.4. You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you.

5.5. If you opt-out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

5.6. For more information about the cookies, we use and how to change your cookie preferences, please refer to our Cookies Policy.

6. Sharing personal information

6.1. We may share your personal information:

6.1.1. within our group of Partnerships and companies including any affiliates.

6.1.2. with third party service providers, including, our insurers and insurance agents, banks, financial institutions or other third-party lenders, IT service providers, auditors and legal professionals to facilitate our business and the services which we provide.

6.1.3. where we are subject to a legal obligation that necessitates the sharing of this information with parties such as our regulatory authorities, tax and revenue authorities, companies’ registries, governmental departments, courts and law enforcement authorities.

6.1.4. in the context of a merger, sale or acquisition, or other change in our organisational structure.

6.2. The third-party service providers to whom your personal information may be transferred are based primarily in the countries / territories where we have a jurisdictional presence but may also be based in other European Economic Area countries, and in a few exceptional circumstances outside of the European Economic Area or those other countries / territories in which we have a jurisdictional presence.

6.3. Where we share your personal information with group companies and/or third party service providers and/or in the context of a change in our organisational structure outside of the UK or the European Economic Area, and where we are not otherwise subject to a legal obligation to share your personal information, then we require the recipients of that personal information to put in place adequate measures to protect it, including by entering into appropriate data sharing agreements such as the UK and EU standard contractual clauses. If you would like further information about the safeguards, we have in place to protect your personal information, please contact mi@miandassociates.com.

7. How does MI & Associates protect data?

7.1. MI & Associates takes the security of your data seriously. MI & Associates has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.

7.2. Where MI & Associates engages third parties to process personal data on its behalf, they do so based on written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

7.3. If you would like further information about the safeguards we have in place to protect your personal information, please contact at mi@miandassociates.com.

8. Retention of personal information

8.1. Your personal information will be retained for as long as required:

8.1.1. for the purposes for which the personal information was collected.

8.1.2. in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations; and/or

8.1.3. as required by data protection laws and any other applicable laws or regulatory requirements.

8.2. If we rely on consent to process your personal information, you are free to withdraw your consent at any time.

8.3. For further information about applicable retention periods, please contact: mi@miandassociates.com.

9. Access to and control of personal information

9.1. Depending on the country or territory in which our processing of your personal information takes place and/or where you are you may have some or all of the following rights (although these may only be exercisable in certain circumstances) in respect of the personal information about you that we process:

9.1.1. the right to access and port personal information;

9.1.2. the right to not provide or withdraw consent;

9.1.3. the right to correct inaccurate, incomplete or out of date personal information;

9.1.4. the right to restrict the use processing of personal information;

9.1.5. the right to have personal information erased;

9.1.6. the right to object to processing of personal information;

9.1.7. the right not to be subject to a decision based solely on our automated processing of your personal information;

9.1.8. the right to compensation where we or another organisation has caused you damage as a result of the processing of your personal information; and

9.1.9. the right to seek a judicial (i.e. court) remedy where you consider we have acted or are about to act in breach of the relevant data protection legislation.

9.2. You also have the right to lodge a complaint about our handling of your personal information with a relevant data protection supervisory authority either in the country/territory in which you are located and/or in the jurisdiction in which we are located and process your personal information.

9.3. Whenever you are considering lodging a complaint however, we should please be grateful if you would first allow us the opportunity to resolve your complaint by addressing it in writing, and providing as much detail as possible, to mi@miandassociates.com.

9.4. Where we have relied on consent to process your personal information, you have the right to withdraw consent at any time.

9.5. If you wish to receive more information about your data protection rights or to exercise any of your rights, please contact mi@miandassociates.com.

10. Inaccurate or amended information

10.1. Please let us know as soon as possible if any of your personal information changes (including your correspondence details).

10.2. Failure to provide accurate information or to update information when it changes may have a detrimental impact upon our ability to provide services.

11. Changes to this privacy notice We reserve the right to update this Privacy Notice at any time and keep it under regular review.

12. Questions If you have any questions about this Privacy Notice or how we handle your personal information (e.g. our retention procedures or the security measures we have in place), or if you would like to make a complaint, please contact mi@miandassociates.com.

By choosing to “Accept All Cookies” and using the MI & Associates website you’re confirming that you’re happy with MI and Associates use of cookies. This page tells you more about what cookies are and how we use them. MI & Associates reserves the right, at its sole discretion, to alter and update this Cookie Policy from time to time. We therefore invite you to review the current version of Cookie Policy each time you return to our Site.

What are cookies?

Cookies are small data files that are placed onto your computer’s hard drive or in your web browser memory when you visit a website. Almost every website uses cookies.

What are cookies for?

Cookies help to make your experience of using a website better. For example, they can remember the information you supply as you register with a website so that you can sign in with one click next time. What cookies don’t do is store any confidential information about you personally. The cookies on our website simply allow us to track generic usage of our website – not your individual usage behaviour.

Types of cookies that may be used during your visit to the website:

The following type of cookies is used on this site. We don’t list every single cookie used by name – but for each type of cookie we tell you how you can control its use.

1. Analytics cookies

These monitor how visitors move around the Website and how they reached it. This is used so that we can see total (not individual) figures on which types of content users enjoy most, for instance.

You can opt out of these if you want.

Where you provide your consent, we use Google Analytics (Data privacy and security – Analytics Help (google.com) ) cookies to collect information about how you use miandassociates.com. This includes IP addresses.

Google Analytics processes information about:

• the pages you visit on miandassociates.com
• how long you spend on each miandassociates.com page
• how you got to the site
• what you click on while you’re visiting the site

We make sure you cannot be directly identified by Google Analytics data. We do this by using Google Analytics’ IP address anonymisation feature and by removing any other personal data from the titles or URLs of the pages you visit.

We will not combine Google Analytics information with other data sets in a way that would directly identify who you are.

2. Third-party service cookies

Social sharing, video and other services we offer are run by other companies. These companies may drop cookies on your computer when you use them on our site or if you are already logged in to them.

Please refer to the respective platform’s privacy policies.

3. Site management cookies

These are used to maintain your identity or session on the Website. For instance, where our websites run on more than one server, we use a cookie to ensure that you are sent information by one specific server (otherwise you may log in or out unexpectedly). These cookies cannot be turned off individually but you could change your browser setting to refuse all cookies (see above) if you do not wish to accept them.

Are cookies safe?

Yes, they are. Cookies are small text files. They can’t look into your computer or read any personal information or other material on your hard drive. Cookies can’t transmit viruses or install anything harmful on your computer.

Why should I keep cookies turned on?

We would like you to keep cookies active on your computer during your visits to our website because parts of the site rely on them to work properly. For example, you would not be able to view a location map without them.

How can I turn cookies off?

You can at any time change or withdraw your consent from the Cookie Declaration on our website.