Data privacy & cookie notices
1. Introduction
1.1 This data privacy policy applies to (among other products and services) the following apps:
(a) Maximon - legal drafting suite
(b) FD Mxmn - import business data
1.2 This data privacy policy consists of the following sections:
(a) "General": applicable to all data subjects.
(b) Jurisdiction-specific supplements: applicable where, by virtue of domestic data protection law in the relevant jurisdiction, and/or applicable international private law, the Company's processing of your data is subject to the laws of that jurisdiction.
(c) "Cookies": a supplement specifically addressing website cookies.
1.3 The provisions of the supplements described at (b) and (c) above are, insofar as applicable, in addition to, rather than instead of, the general section described at (a) above (of which this introduction forms part).
2. Purpose of this privacy policy
2.1 This privacy policy aims to give you information on how the Company collects and processes your personal data through:
(a) your use of the Company’s website;
(b) your use of the Company’s software-as-a-service (“SaaS”) product offerings (including those listed at 1.1 above);
(c) your registration of a user account; and
(d) your (or your business’s) entry into a subscription agreement with the Company.
2.2 This website is a business website: it is not intended for children and we do not knowingly collect data relating to children.
2.3 It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
2.4 The Company is part of a Group of legal entities. This privacy policy is issued on behalf of the Group, so references to the “Company” or "us" (or declensions of these terms) are meant to refer to the relevant company in the Group responsible for processing your data in any given case. Maximon Ltd. is responsible for data processing in connection with the website.
2.5 The board of the Company is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please submit a request by email to hello@maximon.ltd.
2.6 We keep our privacy policy under regular review. We may update this policy periodically in response to regulatory, policy, or internal changes. In case of change, we will publish the updated version on the Company website.
2.7 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2.8 This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2.9 This privacy policy includes this “general” section and several jurisdiction-specific addenda. The addenda may apply to you by virtue of your location, or may apply generally e.g. by virtue of the data storage locations (as disclosed below) or other legal bases. Where a jurisdiction-specific addendum applies, it is to be read in conjunction with, not instead of, the general section; but in case of conflict, the addenda take precedence.
3. The data we collect about you
3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped as follows:
(a) Identity Data includes name, title, and business affiliation.
(b) Contact Data includes email address, and possibly other contact details such as address or phone number.
(c) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
(d) Technical Data includes internet protocol (IP) address, your login and license identification data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. In respect of error reports, it may also include details of loaded dynamic link libraries, relevant registry information, and configured addins.
(e) Profile Data includes your username and password, and saved preferences.
3.3 We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data); nor do we collect any information about criminal convictions and offences.
3.4 Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
4. How is your personal data collected?
4.1 We use different methods to collect data from and about you including through:
(a) Direct interactions: You may give us your Identity, Contact and Transaction Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
(i) enquire about, or contract for, our products or services;
(ii) create an account on our website;
(iii) subscribe to our service or publications; or
(iv) give us feedback or contact us.
(b) Automated technologies or interactions: As you interact with our website and software, we may automatically collect Technical Data, for example through cookies, automatic error reporting, or server-side logging.
(c) Third parties or publicly available sources: We might receive personal data about you from various third parties and public sources, for example from official company registries or LinkedIn or similar profiles.
5. How we use your personal data
5.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
(a) Where we need to perform the contract we are about to enter into or have entered into with you.
(b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
(c) Where we need to comply with a legal obligation.
5.2 Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending marketing communications to you via email or other means. You have the right to withdraw consent to marketing at any time by contacting us.
5.3 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
5.4 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/activity | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Transaction | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Inviting you to give feedback | (a) Identity (b) Contact (c) Profile | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To administer and protect our business, website, and software (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To use data analytics to improve our website, products/services, and user experiences | (a) Technical | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Profile | Necessary for our legitimate interests (to develop our products/services and grow our business) |
5.5 Change of purpose
(a) We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
(b) If we need to use your personal data for an unrelated purpose, we will notify you (directly or through an update to this privacy notice) and we will explain the legal basis which allows us to do so.
(c) Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Disclosures of your personal data
6.1 We may share your personal data with the parties set out below for the purposes set out in the table above.
(a) Other Group companies
(b) External Third Parties as set out in the Glossary.
(c) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
6.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes.
7. International transfers
7.1 We may transfer your data internationally, most notably (but not exhaustively) between the following jurisdictions:
Singapore | Registered office of FD Mxmn Pte. Ltd. |
Switzerland | Backup site for Group data |
United Kingdom | Data center hosting Group website and email systems |
United States – Colorado | Registered office of Maximon Ltd. |
United States – California | Data center hosting Group SaaS platforms |
7.2 We ensure your personal data is protected:
(a) by requiring all our Group companies to follow the same “binding corporate rules” when processing your personal data; and
(b) by ensuring that destination countries have been deemed to provide an adequate level of protection for personal data, and/or that our service providers in those countries are contractually obligated to provide an equivalent level of protection.
8. Data security
8.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
8.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data retention
9.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.
9.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
10. Glossary
Term | Meaning |
---|---|
Company | The Group company providing the web site or service, as applicable. |
Group | Maximon Ltd., FD Mxmn Pte. Ltd., and other partner and affiliate entities from time to time. |
Legitimate Interest | The interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. |
Performance of a contract | Performance of a contract to which you are a party, or taking steps at your request before entering into such a contract. |
Comply with a legal obligation | Compliance with a legal obligation that we are subject to. |
Internal Third Parties | Other companies in the Group and which are based in Focal Territories, and which provide IT and system administration services and undertake leadership reporting. |
External Third Parties | (a) Service providers based in Focal Territories who provide IT and system administration services. (b) Professional advisers including lawyers, company secretaries, and insurers based in Focal Territories who provide consultancy, banking, legal, insurance and accounting services. (c) Tax authorities and other government regulators in Focal Regulators who may require reporting of processing activities in certain circumstances. |
Focal Territories | The territories listed in paragraph 7.1 above. |
11. History
11.1 Effective date: 29 March 2022
11.2 Last updated: 27 April 2022
© Copyright Maximon Ltd., 2024.
Maximon Ltd., 1942 Broadway St, STE 314C, Boulder, CO 80302, United States of America.
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