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MVM CARD
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Privacy Policy & Personal Data Protection
MVM PLATFORM
Version: 1.0
Effective date: [DATE]
Last updated: [DATE]
Website: https://angel-eyes.ru/
Privacy contact: fksstudio@proton.me

1. Introduction

MVM Platform is a digital platform designed to connect physical and digital identities through a common digital layer.

One of the services provided by MVM Platform is MVM Card — a digital identity card that allows a person to create, manage and share a personal digital profile using a web link, QR code, NFC and other technologies supported by the platform.

We respect the privacy of our users and are committed to handling personal data responsibly, transparently and securely.

This Privacy Policy explains what personal data may be collected through MVM Card and related MVM services, why such data may be processed, how it may be stored and protected, and what rights users have in relation to their personal data.

By using MVM Card or providing personal data to MVM Platform, you acknowledge that you have read this Privacy Policy.

2. Who operates MVM Platform

For the purposes of this Privacy Policy, MVM Platform, MVM, we, us and our refer to the team responsible for developing, maintaining and operating the MVM digital platform and its services.

At the current stage of development, MVM Platform is presented as a product and technology platform rather than through a publicly designated corporate entity.

MVM Platform may in the future operate through one or more legal entities, partners or service providers in different countries or jurisdictions.

When a specific legal entity becomes responsible for a particular processing activity, the relevant information may be updated in this Privacy Policy or provided to users through the relevant service.

For privacy-related questions, requests or concerns, please contact:

MVM Platform
Email: fksstudio@proton.me
Website: https://angel-eyes.ru/

3. What is MVM Card

MVM Card is a digital profile designed for personal identity and contact exchange.

A user may create a card containing information such as:

  • name and surname;
  • photograph;
  • profession or position;
  • organisation or project;
  • short personal or professional description;
  • telephone number;
  • email address;
  • social media and messenger links;
  • website links;
  • other information voluntarily provided by the user.

The user decides what information to add to the card and which information to make publicly visible.

MVM Card may be accessed through:

  • a direct web link;
  • QR code;
  • NFC;
  • digital contact exchange;
  • supported wallet services;
  • other technologies introduced by MVM Platform.

4. Personal data we may process

Depending on the functions used by the user, MVM Platform may process the following categories of information.

4.1. Information provided directly by the user

This may include:

  • name;
  • surname;
  • photograph;
  • professional title;
  • organisation;
  • project name;
  • biography or description;
  • telephone number;
  • email address;
  • social media links;
  • messenger links;
  • website addresses;
  • other information voluntarily entered into MVM Card.

MVM Platform does not require more personal information than is reasonably necessary for the relevant function.

4.2. Technical information

When a user accesses MVM Card or related MVM services, technical information may be processed automatically.

This may include:

  • IP address;
  • date and time of access;
  • browser type;
  • operating system;
  • device type;
  • technical identifiers;
  • session information;
  • error information;
  • security-related logs;
  • other technical information necessary to operate and protect the service.

4.3. Information about interaction with MVM Card

MVM Platform may process information about how a digital card is used.

This may include:

  • card views;
  • date and time of interaction;
  • link clicks;
  • contact-save actions;
  • QR-code interactions;
  • NFC interactions;
  • technical events;
  • aggregated usage statistics.

This functionality may form part of the MVM Pulse system — an analytical layer designed to help users understand how their digital identity is being interacted with.

5. Information voluntarily made public

MVM Card is designed to enable digital identity and contact sharing.

If a user makes information publicly visible through MVM Card, that information may be accessed by other people who receive the card's link, scan its QR code, use an NFC interaction or otherwise access the public profile.

Public information may potentially be:

  • viewed;
  • copied;
  • saved;
  • shared with other people;
  • indexed by search engines where indexing is technically available.

MVM Platform cannot control copies of information made by third parties outside the platform.

Users should therefore publish only information they are comfortable making publicly available.

6. Purpose of processing

Personal data may be processed for the following purposes:

  1. creating and maintaining MVM Card;
  2. providing digital identity and profile functionality;
  3. displaying information selected by the user;
  4. enabling contact exchange;
  5. operating QR and NFC functionality;
  6. enabling sharing and saving of digital contact information;
  7. providing supported wallet and digital-card functionality;
  8. maintaining account and service security;
  9. preventing abuse, fraud and unauthorised access;
  10. troubleshooting and technical support;
  11. measuring and analysing the use of MVM services;
  12. developing and improving MVM Platform;
  13. complying with applicable legal obligations;
  14. protecting the rights, security and legitimate interests of MVM, users and third parties.

MVM Platform aims to process only information that is reasonably necessary for the relevant purpose.

7. Legal basis for processing

Depending on the particular processing activity and the law applicable to that activity, personal data may be processed on one or more of the following grounds:

  • the user's consent;
  • the necessity of processing to provide a requested service;
  • the necessity of processing to perform an agreement;
  • compliance with a legal obligation;
  • protection of legitimate interests;
  • protection of vital interests;
  • another legal basis permitted by applicable data protection legislation.

Where consent is used as the legal basis, MVM Platform will seek to obtain it in a clear and understandable manner.

Where applicable law requires consent to be separate from acceptance of other terms, the relevant consent will be requested separately.

Where processing is necessary to provide the requested MVM service, such processing may be based on a legal ground other than consent.

8. Consent

Where processing is based on consent, the user provides consent voluntarily and for a specified purpose.

For MVM Card, the user interface may contain a confirmation such as:

☐ I agree to the processing of my personal data in accordance with the Privacy Policy.

[ GET MY MVM CARD ]

Consent records may include:

  • date and time of consent;
  • version of the Privacy Policy applicable at the time;
  • MVM Card or account identifier;
  • technical information necessary to demonstrate the consent.

Where consent is the applicable legal basis, users may withdraw consent at any time.

Withdrawal of consent does not affect the lawfulness of processing that took place before withdrawal. Where applicable law requires it, withdrawal should be as easy as giving consent.

If withdrawing consent makes it impossible to provide a particular MVM function, that function may no longer be available to the user.

9. Marketing communications

MVM Platform does not intend to make marketing communications a condition for receiving an MVM Card.

Where marketing communications require consent, that consent may be requested separately.

For example:

☐ I would like to receive news and information about MVM products and services.

Users may withdraw marketing consent or unsubscribe from marketing communications.

10. MVM Pulse and usage analytics

MVM Pulse is an evolving component of MVM Platform intended to provide useful information about interaction with digital identities.

Depending on the functionality available at a particular time, MVM Pulse may provide statistics such as:

  • number of card views;
  • number of contact saves;
  • number of link interactions;
  • QR-code usage;
  • NFC usage;
  • technical information;
  • aggregated activity statistics.

MVM Platform aims to design analytics in a privacy-conscious manner.

Where possible, statistics may be aggregated or otherwise presented without revealing unnecessary personal information about individual visitors.

If future versions of MVM Pulse introduce new types of personal analytics, MVM Platform may update this Privacy Policy and provide additional information where required.

11. Location information

Some future MVM functionality may involve geographic or location-related information.

MVM Platform will not intentionally collect precise device location merely because a person opens an MVM Card unless the relevant function requires it and the necessary permission or other legal basis exists.

If location-related functionality is introduced, the relevant processing will be described separately and transparently.

12. Data relating to other people

MVM Card allows users to publish information that may identify other people, for example through photographs, organisation information or contact references.

Users must not upload or publish personal data relating to another person unless they have an appropriate legal basis or permission to do so.

Users remain responsible for the information they choose to publish through their MVM Card.

13. Sensitive personal data

MVM Card is not designed to collect or publish sensitive or special categories of personal data.

Users should not voluntarily add information concerning:

  • health or medical conditions;
  • political opinions;
  • religious or philosophical beliefs;
  • sexual orientation or sex life;
  • biometric information;
  • criminal convictions or offences;
  • other sensitive information requiring special protection, unless a particular MVM service explicitly supports such processing and an appropriate legal basis exists.

14. Third-party service providers

MVM Platform may use third-party providers to operate and maintain its services.

Depending on the technical architecture, these may include providers of:

  • hosting and server infrastructure;
  • cloud storage;
  • databases;
  • content delivery;
  • email services;
  • technical monitoring;
  • analytics;
  • security services;
  • QR and NFC functionality;
  • digital wallet integrations;
  • authentication;
  • customer support;
  • other infrastructure required to provide MVM services.

Third-party providers may process personal data only to the extent reasonably necessary for the relevant service and subject to applicable legal and contractual requirements.

The technical infrastructure of MVM Platform may change as the platform develops.

15. International data processing

MVM Platform is intended as an international digital service.

Depending on the technical infrastructure, users and service providers involved, personal data may be processed or stored in countries different from the country in which the user lives.

Where applicable law imposes requirements on international transfers of personal data, MVM Platform will apply the safeguards required by that law.

This may include appropriate contractual, organisational, technical or other legally recognised safeguards.

16. Data retention

MVM Platform does not intend to keep personal data longer than reasonably necessary for the purpose for which they were collected, unless a longer retention period is required or permitted by applicable law.

As a general principle:

  • MVM Card information may be retained while the card remains active;
  • account-related information may be retained while necessary to provide the service;
  • technical and security logs may be retained for a limited period necessary for security and troubleshooting;
  • consent records may be retained for as long as reasonably necessary to demonstrate the existence and scope of consent;
  • information may be retained longer where necessary to comply with legal obligations or establish, exercise or defend legal claims.

When personal data are no longer required, they may be deleted, destroyed or anonymised.

17. Deleting an MVM Card

A user may request deletion of their MVM Card and associated personal information.

Requests may be sent to:

fksstudio@proton.me

The request should, where possible, include:

  • the MVM Card link;
  • MVM ID or other card identifier;
  • the email address associated with the card;
  • a description of the requested action.

MVM Platform may request reasonable information necessary to verify that the request was made by the relevant user.

Some information may be retained where required by law or where reasonably necessary to establish, exercise or defend legal claims.

18. User rights

Depending on the law applicable to the relevant processing, users may have rights including:

  • the right to know whether personal data are being processed;
  • the right to access personal data;
  • the right to correct inaccurate or incomplete information;
  • the right to request deletion;
  • the right to request restriction of processing;
  • the right to object to certain processing;
  • the right to withdraw consent where processing is based on consent;
  • the right to receive information about processing purposes and recipients;
  • the right to data portability where applicable;
  • the right to lodge a complaint with a competent data protection authority;
  • other rights provided by applicable law.

Requests relating to personal data may be submitted to:

fksstudio@proton.me

MVM Platform will handle such requests in accordance with the law applicable to the relevant processing.

19. Security

MVM Platform takes reasonable technical and organisational measures intended to protect personal data against:

  • unauthorised access;
  • unauthorised disclosure;
  • accidental loss;
  • destruction;
  • alteration;
  • misuse.

Depending on the system, such measures may include:

  • access controls;
  • authentication;
  • encryption in transit;
  • secure server infrastructure;
  • backups;
  • monitoring;
  • logging;
  • restricted administrative access;
  • security testing;
  • other appropriate technical and organisational safeguards.

No Internet-based service can guarantee absolute security.

20. Security incidents

If MVM Platform becomes aware of a security incident involving personal data, it will take reasonable steps to:

  1. identify and contain the incident;
  2. assess its potential impact;
  3. restore the security of affected systems;
  4. investigate the cause;
  5. take measures to prevent recurrence;
  6. notify affected users or competent authorities where required by applicable law.

21. Cookies and similar technologies

MVM websites and services may use cookies and similar technologies.

These technologies may be used for:

  • essential technical functionality;
  • security;
  • session management;
  • remembering settings;
  • performance monitoring;
  • analytics;
  • other functions necessary to operate or improve the service.

Where applicable law requires consent for non-essential cookies or similar technologies, MVM Platform will request such consent through an appropriate interface.

22. External links and platforms

MVM Card may contain links to third-party services, including:

  • Telegram;
  • VK;
  • Instagram;
  • websites;
  • email services;
  • other social networks or communication platforms.

When a user leaves MVM Platform and accesses an external service, the processing of personal data is governed by the privacy policy and terms of that external service.

MVM Platform does not control the privacy practices of third-party platforms.

23. Children's privacy

MVM Card is not specifically designed to collect personal information from children.

Where applicable law requires parental or guardian consent for processing a child's personal data, MVM Platform will follow the applicable requirements.

If MVM Platform becomes aware that personal data belonging to a child have been submitted without the required legal basis, reasonable steps may be taken to delete such information.

24. User responsibility

Users are responsible for ensuring that the information they provide to MVM Platform is accurate and that they have the right to provide and publish it.

By creating an MVM Card, the user confirms that they will not intentionally use the service to:

  • publish another person's personal data without an appropriate legal basis;
  • publish passwords, authentication codes or confidential credentials;
  • publish financial account information;
  • impersonate another person;
  • publish unlawful or harmful material;
  • use MVM Card for fraudulent or unlawful activity.

MVM Platform may restrict or remove content or cards that violate applicable law or the rules of the platform.

25. Changes to this Privacy Policy

MVM Platform may update this Privacy Policy as the platform develops.

Changes may be necessary because of:

  • new MVM functionality;
  • changes in technical infrastructure;
  • new data processing activities;
  • changes in applicable law;
  • changes in service providers;
  • changes in the organisational structure of MVM Platform.

The current version will be published on the MVM website.

The Last updated date will be changed whenever the document is materially revised.

Where applicable law requires additional notice or renewed consent for a material change, MVM Platform will provide such notice or request such consent.

26. Applicable privacy laws

MVM Platform is intended to operate internationally.

Personal data may therefore be subject to different privacy and data protection laws depending on:

  • the location of the user;
  • the location of the relevant MVM operator;
  • where the data are processed;
  • the nature of the service;
  • the circumstances of the processing.

MVM Platform intends to process personal data in accordance with the data protection and privacy laws applicable to the relevant processing activity.

Where specific privacy regulations apply to a user or a particular MVM service, those regulations may provide additional rights or obligations beyond those described in this general Privacy Policy.

This Privacy Policy is not intended to exclude or limit rights that cannot lawfully be excluded or limited under applicable law.

27. Contact

For questions about this Privacy Policy, personal data, deletion requests, access requests or other privacy matters:

MVM Platform

Email: fksstudio@proton.me

Website: https://angel-eyes.ru/

28. Consent to personal data processing

For the creation of an MVM Card, the user may be presented with the following confirmation:

☐ I agree to the processing of my personal data for the creation and operation of my MVM Card in accordance with the MVM Privacy Policy.

[ GET MY MVM CARD ]

Where required, a separate optional consent may be displayed:

☐ I would like to receive news and information about MVM products and services.

Marketing consent is separate from consent necessary for the operation of MVM Card.

MVM Platform

Identity. Connect. Pulse.

Privacy contact: fksstudio@proton.me
Website: https://angel-eyes.ru/

Privacy Policy v1.0