2. Personal Information
3. Privacy Principles
4. Why does Movati collect personal information?
5. Privacy and our websites
6. How to obtain access to personal information
7. How does Movati protect personal information?
9. Further information
2. Personal Information
3. Privacy Principles
Principle 1 – Accountability
Principle 2 – Identifying Purposes for Collection of Personal Information
Movati identifies the purposes for which personal information is collected at or before the time the personal information is collected. Some of the identified purposes for which Movati collects, uses or discloses personal information are described in Section 4 below.
Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of an individual are required for the collection, use, or disclosure of his or her personal information, except where inappropriate or as permitted by law. In obtaining consent, Movati uses reasonable efforts to ensure that an individual is advised of the identified purposes for which his or her personal information will be used or disclosed. In determining the appropriate form of consent, Movati has taken into account the sensitivity of the personal information and the reasonable expectations of a reasonable person. An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the Movati Privacy Officer. The implications of such withdrawal are described above.
Principle 4 – Limiting Collection of Personal Information
Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information
Principle 6 – Accuracy of Personal Information
Personal information held by Movati is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. Movati does not routinely update personal information unless it is necessary to do so in order to fulfill the identified purposes. We rely on individuals to inform us of any changes to their personal information. To update personal information, please see Section 9.
Principle 7 – Security Safeguards
Movati uses industry standard security measures to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, modification, disposal or destruction. Personal information disclosed by Movati to third parties is subject to contractual agreements which stipulate the confidentiality of the information and the limited purposes for which it is to be used.
Principle 8 – Openness Concerning Policies and Practices
Principle 9 – Individual Access to Personal Information
Upon written request from an individual pursuant to Principle 8, Movati will inform the individual of the existence, use, and disclosure of his or her personal information and, subject to certain very limited exceptions, will give the individual access to that information. If access is granted, Movati will give the requesting individual a reasonable opportunity to review the personal information collected and stored by Movati. Personal information will be provided in an understandable form within a reasonable time, generally within 30 days, and at minimal cost to the individual. Movati may extend such 30 day period by up to an additional 30 days if meeting the time limit would unreasonably interfere with the activities of Movati or the time required to undertake any consultations necessary to respond to the request would make the time limit impracticable to meet. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate. If access is lawfully denied, Movati will notify the requesting individual in writing, give reasons for the denial, and inform the individual of the recourses open to him or her.
Principle 10 – Challenging Compliance
4. Why does Movati Collect Personal Information?
Movati and its agents, affiliates and service providers may collect, use and/or disclose personal information for the following purposes:
(a) to consider whether Movati should establish or continue a commercial relationship, including without limitation, to extend credit and to evaluate credit standing and to match credit bureau or credit reporting agency information, to check references and to confer with banking institutions; (b) to establish and maintain commercial relations with clients, investors, shareholders, suppliers, financial institutions, insurers, and affiliates, and to provide ongoing products and services, administer accounts, make and receive payments, and fulfill contractual obligations; (c) to understand and respond to client needs and preferences, including to communicate with clients and to provide them with support and other services; (d) to conduct surveys, contests and promotions; (f) to distribute newsletters, press releases, promotional information and other material to individuals, in any format or media, including via third party mailing houses; (g) to develop, enhance, market, sell, provide, and inform individuals of Movati’s products and services; (h) to develop, enhance, market, sell, provide, and inform individuals of products and services of third parties, including affiliates and suppliers with whom Movati has a commercial relationship; (i) to manage and develop Movati’s businesses and operations; (j) to update and verify our databases and information provided by third parties; (k) to detect and protect Movati and other third parties against error, negligence, breach of contract, theft, fraud and other illegal activity, to comply with Movati’s audit requirements, and to engage in audit compliance further to Movati’s corporate policies, procedures, laws and contractual obligations; (l) to engage in and carry out business transactions that may involve the sale or transfer of personal information, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Movati or its affiliates; (m) as permitted by, and to comply with, any legal or regulatory requirements or laws; (n) to send commercial electronic messages to clients and potential clients; and (o) for any other purpose to which an individual consents.
In addition to the above purposes, from time to time Movati may disclose personal information to:
(1) its service providers, including an organization or individual retained by Movati to perform functions on its behalf or to provide services to Movati, such as marketing, data processing, software development, website hosting, information technology and office services, and further provided such organization or individual does not collect, use or disclose the personal information for any purpose other than to perform such functions or provide services to Movati;
(3) a person who, in the reasonable judgment of Movati, is providing or seeking the information as an agent of the subject individual; and
(4) any third party or parties, with the consent of the subject individual or where disclosure is required or permitted by law.
5. Privacy and our Websites
On-line and Off-line Communications – In order to provide you with a product, service or information, you may voluntarily submit personal information to us for purposes such as registering for our services, obtaining information, corresponding with us (including through electronic means), and participating in contests and surveys. We may combine and store personal information about your use of our website and the online information you have provided with certain other online and offline information we may have collected.
Electronic Communications – If you send us an inquiry from our website, Movati may send you electronic communications with information that may be useful to you, including information about Movati and other third parties with whom we have a commercial relationship. We will include instructions on how to unsubscribe and inform us of your preferences if you decide you do not want to receive any future marketing or promotional electronic messages from Movati.
Links – Our website may contain links to other websites which are provided to you as a convenience only. You are advised that personal information you submit through other third party websites will be governed by the respective policies and privacy practices of those websites, if any. Movati has no responsibility for such third party websites.
6. How to Obtain Access to Personal Information
Upon your written request and subject to certain exceptions, Movati will inform you of the existence, use and disclosure of your personal information and will give you access to that information. Access requests must be sent in writing to our Privacy Officer at the contact information in Section 9 below.
7. How does Movati Protect Personal Information?
To help guard the confidentiality of personal information, Movati uses industry standard administrative and technological safeguards appropriate to the sensitivity of the personal information. For instance, we operate secure data networks protected by firewall and password protection systems. Personal information is stored in secured locations and on servers controlled by Movati, located either at our offices or at the offices of our service providers. Personal information collected will be destroyed, erased or made anonymous when it is no longer required to fulfill the purposes for which it was collected.
9. Further Information
For more information about Movati’s privacy practices, to amend or obtain access to your personal information, to opt-out or withdraw your consent, or if you have privacy-related questions or concerns, please contact our Privacy Officer at:
Movati Privacy Officer
400-33 University Avenue W
Attention: Charlie Simpkins, CIPP/C