At REC.VC and our company Media Network Services AS (“MNS” or “We” or the “Company”), we sincerely care about privacy, security, and transparency; these core elements play a substantial role in our company’s mission. Toward that, this privacy notice (“Notice”) explains several matters including the following:
MNS may have two possible relationships with you. First, if your subscription was purchased directly from MNS, then we are acting as a Controller under European Union definition, and we have responsibilities associated with a Controller’s obligations such as ensuring you have the right to access to your information, the right to correct your information, and many other privileges granted under various regulations.
Second, if your subscription was purchased through a service provider or reseller, they may be acting as the Controller and MNS is acting as the Processor. As such, your service provider or reseller must work with you to access your information, make corrections when you request it, and so on. In that scenario, MNS as the Processor will work with the Controller (your service provider or reseller) to ensure your rights are upheld in a timely manner.
As our business grows and our Services evolve, this Notice may change, or other privacy notices may be written and posted specific to new offerings or to keep pace with data privacy laws. When changes are substantial, we will first ensure to make you aware of any forthcoming changes by attempting to contact you directly via email, or via our user interfaces, or via indirectly through your service provider or reseller. Should we contact you in the future about privacy notice changes, you can respond in writing to email@example.com; we want to hear from our customers and answer any questions.
When visiting any of our websites, we use a third-party analytics service called Google Analytics to collect, analyze and tally metrics regarding visitors and behaviour. Analytics collected help us to determine many things, including the quantity of visitors over time, the geographic location from which visitors arrive, timeframes of high and low usage, the sites most frequented, the pages most frequented, and other helpful data. The Company processes data in ways to ensure individual identity is not stored, only anonymous metrics. Furthermore, it is forbidden for Google to determine, or attempt to determine, the identity of individuals visiting our websites.
Information we collect is stated clearly and transparently in this Notice, including an explanation about why we are collecting the information, how we store it, where we store it, with whom it might be shared, the purpose for which it is collected, and how to contact us.
For instance, when a consumer purchases a direct subscription to rec.vc, we must collect various details employing a “know-your-customer” (“KYC”) approach. In this context, we may collect data elements such as name, email address, geographic location, and payment information via third parties such as Shopify and Stripe to complete the transaction. Geographic information is collected for localization (date format, regional settings) as well as regulatory compliance with regulatory authorities.
The personal information you provide to MNS or its service provider is voluntary. If you do not want MNS to store your personal data, the Company and its service providers and resellers will not be able to provide any Services to you, and the service will not be initiated or it will be terminated if personal data is revoked.
The types of personal information we collect depends on the service subscription; different types of information may be collected from a website compared to the types of data collected from our Services. In most cases, the information collected contains:
There may also be instances when we collect other information related to Service usage (“Usage Data”). Much of this data is employed in aggregate, and anonymized, permitting MNS to compared which features are employed more frequently, and which features less frequently. In some cases, Usage Data may be gathered by the employment automatic data gathering technology such as Google Analytics (previously mentioned) or cookies; see the section regarding cookies to better understand how and why we employ cookies.
At MNS, we may also gather information about the type of computer systems you use, including associated devices such as microphones and video cameras as these are relevant to the Services offered by MNS. The information may also include your IP address, operating system, browser type, language preferences, and other relevant details to help MNS ensure your service is working correctly.
There are a few ways we may collect information about you. The information we hold may have come from you directly, we may have collected it automatically, or it may have come from other sources, such as a service provider with whom you purchased our Services.
Information Received from You Directly: When we receive information from you directly, it usually involves your contact details, payment information, information related to the service you request, responses to surveys, requests for help, etc. In those cases, you decide how much information to provide. Certain types of information are baseline in order to enable the service (such as payment details and name). Sources related to information we may have receive directly from you include:
Information Received Indirectly: When you surf our Websites or employ our Services, we receive information and store that information automatically, such as Usage Data. We also receive and store information about your browser or your mobile device. Other types of information may include your IP address, preferred language, operating system, browser type, geographic location using IP geolocation services, Bluetooth information, computer platform, purchase history, URL clickstream, timestamp of activity, history of products viewed, pages visited, products reviewed, etc. We may also choose to log the length of time you spend reviewing a page or the number of times you return to a page, because that information is helpful to us in terms of which products in which you are interested. These activities are normally tracked by cookies or web beacons; more information is available about cookies below.
Information from Other Sources: There may be times when we receive information about you from other sources, such as through a service provider through whom you subscribe to a service. For example, you may purchase a subscription to rec.vc through another company, and that company has provided to MNS your details for service activation. We may also receive information about you through credit agencies or rating agencies, if applicable and if appropriate.
There are many reasons why MNS uses your personal data. Some of these include service activation, service support, service billing, service termination, service metrics, and marketing research.
Service Activation: To activate your service, MNS uses your email address as your login identifier that, when validated by your password, provides access to the Services purchased. These two elements are stored and used to access any of the Services offered by MNS.
Service Support: Contact details are stored for MNS to support service requests that may be initiated by you, the customer, through the process of opening a ticket or submitting an inquiry about any Services.
Service Billing: Billing information is necessary to initiate Services, unless the service is a trial of any MNS Services. Billing information may not be necessary if Services are initiated by a service provider.
Service Termination: Your personal information may be used to initiate and complete a service termination request, initiated by you or a service provider.
Service Metrics: Your information may be associated with service metrics, including Services used as well as the frequency, volume and behaviour of Services employed. This enables MNS to focus its development resources on the features and services you find most worthwhile.
Marketing Research: Regarding the Websites you visit, it is helpful to MNS to understand how you arrived to the site, whether from a Google search, a LinkedIn post, an advertisement, or direct access. Measuring which of our marketing activities is the most productive is helpful to MNS regarding future advertising campaigns, and we measure this information in the aggregate to make best use of those efforts.
At MNS, we respect your privacy and we do not use your personal information in any other way beyond what has been written in this Notice. For instance, we do not sell your information to anyone, including but not limited to third parties for their own marketing use, unless we specifically ask you and receive your consent as required by law.
Consistent with this Notice, we may share your information in these ways:
We will not share the following information with any third party, and no third party has access to the following information other than your service provider and reseller; this prohibition against MNS sharing the following information means we will not share:
MNS employs cookies which are small text files stored on your computer, smartphone, tablet or other devices to handshake with our Websites and Services. Cookies enable MNS to streamline many functions, including:
MNS may also employ web beacons to facilitate the delivery of cookies, gather Usage Data, and collect performance metrics. It is also possible that our Services may employ cookies and web beacons from third-party service providers and resellers.
You have several tools that provide control of the user of cookies and web beacons, including those built into browsers that permit the blocking and deletion of these technologies. You also have the right to opt out of data collection through web beacons and similar technologies. Contact firstname.lastname@example.org for more information about this topic.
At MNS, we have security teams actively working to keep your information protected, reviewing our security posture and improving our shield from unauthorized access, accidental loss, disclosure or destruction. Toward this, we employ physical, technical, administrative, and organisational safeguards to protect the personal information we collect and process. Administrative and organisational policies and procedures are documented in the MNS Information Security Management System (ISMS) where appropriate controls are designed to maintain an adequate level of data confidentiality, integrity and availability. We also test the MNS continuity of operations plan supporting our Services, including the core infrastructure and networking components distributed throughout our global data centers.
Third-party auditing is performed by an independent security and compliance firm, ensuring administrative, physical, technical and organisational measures meet compliance requirements. Attestations of compliance are made available independently, along with risk management and technical vulnerability management evidence of practice.
Guiding Principles: At MNS, we maintain the following guiding principles for security and compliance:
MNS supports an ongoing risk management lifecycle to:
Risk Assessment and Analysis: MNS maintains risk assessment measures to identify information security risks across its IT environment, including application software, databases, operating systems, servers, and other equipment, such as network components and network services. MNS coordinates risk assessment activities that may take several forms and involve third party auditors, including analyses, audits, reviews, vulnerability scans, and penetration testing.
Remediation and Mitigation Plans: MNS maintains and oversees remediation and mitigation plans to address risk assessment findings according to risk levels.
Technical Vulnerability Management: MNS practices ongoing technical vulnerability management, subscribing to vulnerability databases to ensure MNS is aware of vulnerabilities in hardware and software that might arise. MNS also scans its environment for vulnerabilities and employs using an independent firm to test the security posture of MNS service from an external vector and an internal vector. Issues found are noted through an incident management process, ensuring weakness are addressed that keep the MNS security posture strong.
MNS is committed to the highest standards of information security, privacy and transparency. Toward this, MNS complies with the GDPR as both a data controller and a data processor. Additional highlights related to GDPR compliance are as follows:
MNS may be acting as the Controller or the Processor in relation to your data. Either way, MNS commits to ensure all rights for individuals are upheld, including:
For any questions regarding the MNS commit to GDPR or any processes we follow, please contact email@example.com.
Consistent with GDPR’s minimalization principle and its limitation principle, we retain data only as long as required to meet business purposes, such as contractual obligations, billing and reporting, taxation purposes, and other relevant reporting and reconciliation purposes. We do not hold data longer than the law permits, ensuring the data retention period is lawfully justified. As a general rule, MNS holds data for the contract term plus twelve months. Once the data retention period is effectuated, data is anonymized for historical trending, capacity management, and other permissible business purposes for which anonymized data is helpful. Further, conferencing recordings are purged, including any backup copies of such recordings.
If you are located in the European Economic Area (EEA) or Switzerland, MNS provides adequate levels of protection for your data according to regulatory requirements of EU Regulation 2016/679. When applicable, if data (such as Usage Data) needs to be shared with another entity such as your service provider or reseller that may be located outside of the EEA, we provide adequate levels of protection through a series of Standard Contractual Clauses authorized under the European Commission.
MNS hosts its Services from data centers worldwide, and as such, is required to comply with many national laws and regulations wherever data processing occurs. In that regard, this Notice and the MNS practices comply with the obligations set forth in the following general regulations:
This Notice also complies with the following sectoral regulations which may be relevant to the Services consumed by some subscribers:
Privacy Laws of states in the United States of America have been vetted, and MNS policies and practices take into consideration the requirements of all states, with California leading the way in the privacy arena, having enacted multiple privacy laws, some of which have far-reaching effects at a national level. Some laws have enacted requirements to avoid a security breach such as Massachusetts Regulation (201 CMR 17.00), which prescribes in considerable detail an extensive list of technical, physical and administrative security protocols aimed at protecting personal information that affected companies must implement into their security architecture, and describe in a comprehensive written information security programme. For customers in these states such as California and Massachusetts, MNS meets the requirements imposed.
The MNS website, online content and Services are not directed at children under the age of 13. MNS does not knowingly solicit, collect, use or otherwise disclose the personal information of any nature whatsoever of a person under the age of 13, nor does MNS knowingly allow persons under the age of 13 to utilize any of its Services. In the event that we learn we have collected personal information from a child under the age of 13 without requisite parental consent, we will delete that information as quickly as reasonably possible. If you believe that we have collected information about your child in error, or have questions or concerns about our practices relating to children, please notify us using the Contact Us details and we will promptly respond.
If there are questions or comments about this Privacy Notice, please contact us by email at firstname.lastname@example.org or by call us at +47 2109 5960. You may also write to us at:
Media Network Services AS
Attn: Privacy Office
Karenslyst Allé 8a
0278 Oslo, Norway
At any time, you are permitted under law to receive a copy of the information we hold about you.
If you believe that MNS possesses inaccurate information about you, please contact us and explain the nature of your concern. MNS will research the matter; maintaining accurate data is important to our organisation.
If you want to discontinue receiving marketing messages from us, please click “Unsubscribe” from the latest marketing email sent, or write to email@example.com and we will ensure your name and email address are removed from any marketing list. You will be opted out of any future communication.