Privacy Policy for Middles Man
Last Updated: 02/01/2025
1. Introduction
Welcome to Middles Man (“we,” “us,” or “our”). Your privacy is paramount to us, and we are committed to safeguarding your personal information. This Privacy Policy outlines how we collect, use, disclose, and protect your data when you access or use our website middlesman.com, engage with our services, or interact with us in any other manner. By using our services, you agree to the practices described in this policy.
2. Definitions
- Personal Information: Any information that can identify an individual, either directly or indirectly.
- Non-Personal Information: Data that does not identify a specific individual. However, when combined with personal information, it may become identifiable.
- GDPR: General Data Protection Regulation, a comprehensive data protection law in the European Union.
3. Information We Collect
We gather various types of information to provide and enhance our services effectively. The information we collect falls into the following categories:
A. Information You Provide Directly
When you use our services, you may be prompted to provide certain personal information through various channels, including our website, mobile applications, customer support, and in-person interactions.
Types of Information Collected:
- Account Information: Username, password.
- Contact Details: Email address, phone number.
- Address Information: Residential address, billing address.
- Identity Verification: Full name, government-issued identification (e.g., passport, driver’s license), proof of address (e.g., utility bill).
- Financial Data: Credit card information, bank account details, payment processor information (e.g., PayPal, Skrill), tax identification numbers.
- Transaction Details: Descriptions, attachments related to transactions.
B. Information from Third Parties
We may receive information about you from third-party sources to enhance our services and ensure secure transactions.
Types of Information Collected:
- Contact Information: Email addresses, phone numbers.
- Financial Details: Transaction histories, payment account information.
- Publicly Available Data: Information from public records or other publicly accessible sources.
C. Information Automatically Collected
When you interact with our services, certain information is collected automatically to help us understand your usage patterns and improve your experience.
Types of Information Collected:
- Technical Data: IP address, device type, operating system, browser type, and other device-specific information.
- Usage Data: Pages visited, links clicked, time spent on pages, search queries.
- Interaction Data: Actions taken on our platform, such as initiating a transaction or contacting support.
4. How We Use Your Information
We utilize the information we collect for various purposes to provide and enhance our services:
- Service Delivery: To facilitate and manage transactions between buyers and sellers.
- Account Management: To create and maintain your user account.
- Customer Support: To respond to your inquiries, provide assistance, and resolve issues.
- Communication: To send you updates, newsletters, marketing materials, and important notifications (you can opt out of marketing communications at any time).
- Improvement of Services: To analyze usage patterns, conduct research, and develop new features.
- Security: To protect against fraud, unauthorized access, and other security threats.
- Legal Compliance: To adhere to applicable laws, regulations, and legal processes.
Legal Basis for Processing:
We process your personal information based on the following lawful grounds:
- Consent: When you have given clear consent for us to process your personal data for specific purposes.
- Contractual Necessity: When processing is essential for the performance of a contract you are part of.
- Legal Obligations: When processing is required to comply with legal obligations.
- Legitimate Interests: When processing is necessary for our legitimate interests, provided it does not override your rights.
5. Sharing Your Information
We may share your personal information with third parties under the following circumstances:
A. Transaction Participants
Your information may be shared with other parties involved in a transaction, such as:
- Counterparties: Buyers and sellers participating in the transaction.
- Brokers and Affiliates: Partners assisting in facilitating transactions.
B. Service Providers
We engage third-party service providers to support our operations. These providers are contractually obligated to use your information solely for the purposes we specify.
Categories of Service Providers:
- Payment Processors: Companies handling transactions and payments.
- Cloud Services: Providers managing data storage and infrastructure.
- Communication Services: Email and SMS providers.
- Analytics and Marketing: Firms assisting with data analysis and promotional activities.
- Security Services: Providers ensuring the safety and integrity of our platform.
C. Legal Requirements
We may disclose your information when required by law, such as in response to subpoenas, court orders, or other legal processes. We may also share information to protect our rights, privacy, safety, or property, as well as that of our users and the public.
D. Business Transfers
In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the new entity. We will notify you of any such changes and ensure that your information remains protected.
6. Data Security
We implement robust security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:
- Encryption: Protecting data in transit and at rest.
- Access Controls: Limiting access to personal information to authorized personnel only.
- Regular Audits: Conducting security assessments to identify and mitigate vulnerabilities.
- Incident Response: Having procedures in place to address and respond to security breaches promptly.
7. Your Rights
Depending on your location, particularly if you are in the European Union, you may have certain rights regarding your personal data:
- Access: You can request access to the personal information we hold about you.
- Rectification: You have the right to correct inaccurate or incomplete data.
- Erasure: Under certain conditions, you can request the deletion of your personal information.
- Restriction of Processing: You may request that we limit the processing of your data under specific circumstances.
- Data Portability: You have the right to obtain and reuse your personal data for your own purposes across different services.
- Objection: You can object to the processing of your data based on legitimate interests or direct marketing.
To exercise any of these rights, please contact our Privacy Officer using the contact information provided below. We will respond to your request within a reasonable timeframe and in accordance with applicable laws.
8. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to enhance your experience on our website, analyze usage patterns, and improve our services. You can manage your cookie preferences through your browser settings.
Types of Cookies We Use:
- Essential Cookies: Necessary for the basic functioning of our website.
- Performance Cookies: Help us understand how visitors interact with our site.
- Functional Cookies: Enable enhanced functionality and personalization.
- Advertising Cookies: Used to deliver relevant advertisements to you.
9. Third-Party Links
Our website may contain links to third-party websites and services that are not operated by us. We are not responsible for the privacy practices of these external sites. We encourage you to review the privacy policies of any third-party websites you visit before providing them with your personal information.
10. Children’s Privacy
Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently received personal information from a minor, we will take steps to delete such information from our records.
11. International Data Transfers
As a global company, your personal information may be processed in countries other than your own. We ensure that such transfers comply with applicable data protection laws and that your information remains protected through appropriate safeguards.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any significant changes by posting the updated policy on our website and updating the “Last Updated” date. We encourage you to review this policy periodically to stay informed about how we are protecting your information.
13. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Privacy Officer:
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By Email: privacy@middlesman.com
For individuals in the European Union, our Privacy Officer also serves as our Data Protection Officer (DPO). If you are located in the EU and wish to lodge a complaint regarding our handling of your personal data, you may contact your local Data Protection Authority (DPA). A list of DPAs is available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
