SERVICE DESCRIPTION AND PROVIDER
Millerdale & Kingston Ventures Ltd ("Millerdale & Kingston Ventures," "we," "us," or "our") is committed to respecting your privacy and safeguarding your personal data. We operate as an investment-focused organization, offering the general public various related services and resources such as websites, information inquiries, and more (collectively, the "Service").
Whenever you access or use our Service, personal data about you may be processed as described in this Privacy Policy. Under the General Data Protection Regulation ("GDPR"), "processing" has a broad meaning: essentially, any time someone, including us, interacts with your personal data in some way. Personal data is any information that can be linked to a specific individual.
Although Millerdale & Kingston Ventures is based in the United Kingdom (or another jurisdiction, as applicable), we treat all personal data in accordance with the GDPR, regardless of your location or nationality.

SCOPE OF THE PRIVACY POLICY
This Privacy Policy explains the categories of personal data we collect, how we process it, and how it is used within the Service. Unless otherwise stated, this Privacy Policy governs only how Millerdale & Kingston Ventures and our contracted service providers ("Vendors") handle your personal data. If you use third-party services not provided by us or our Vendors, please consult those third parties' privacy policies.

CONTACT DETAILS OF THE PROVIDER
If you wish to exercise any right referenced in this Privacy Policy or in applicable data protection regulations, or if you have any questions about this Privacy Policy, please contact us at:
Email: info@millerdalekingston.com

You may also request to review, correct, or delete your personal data held by Millerdale & Kingston Ventures, as described below.

YOUR RIGHTS UNDER THE GDPR
In accordance with the GDPR, you have the following rights:

Right to be informed (Art. 12 GDPR)
You have the right to know how Millerdale & Kingston Ventures processes your personal data. We describe our purposes (why we use your data), our retention policies (how long we keep your data), and third parties we share it with (our Vendors) in this Privacy Policy.

Right of access (Art. 15 GDPR)
You have the right to request access to your personal data processed by us. You can see a summary of what we process in the relevant sections below. For additional details, you can contact us at any time.

Right to rectification (Art. 16 GDPR)
You have the right to ask us to correct or update your personal data if it is inaccurate or incomplete. If you notice any incorrect information that cannot be updated through an automated setting in the Service, please reach out to us.

Right to erasure (Art. 17 GDPR)
You have the right to request the deletion of your personal data under certain circumstances—for example, if the data is no longer needed or if you withdraw previously given consent. We will ensure that any Vendors also delete such data where required. If you have questions about data deletion, please contact us.

Right to restrict processing (Art. 18 GDPR)
You may request that we limit the processing of your personal data when you have concerns about its accuracy or our legal basis for processing it. However, if you continue to use our Service while such a request is pending, we will still process your data as necessary to provide you with the Service.

Right to data portability (Art. 20 GDPR)
You may ask us to export or transmit to another controller the personal data that you have directly provided to us, where this is technically feasible. This does not extend to any data that we have derived from your personal data.

Right to object (Art. 21 GDPR)
Where our data processing is based on a legitimate interest, you may object to such processing at any time if you believe your fundamental rights outweigh our legitimate interest. See the Processing Procedures below for more details on when this basis applies.

Rights in relation to automated decision making and profiling (Art. 22 GDPR)
We do not engage in automated decision-making or profiling as defined under the GDPR.

Right to lodge a complaint (Art. 77 GDPR)
If you believe your personal data is being processed unlawfully or in breach of the GDPR, you may file a complaint with your local data protection authority or the relevant supervisory authority. We fall under the purview of the UK data protection authority (the Information Commissioner's Office, or "ICO") unless otherwise indicated.

When exercising any of these rights, please provide enough information for us to confirm your identity and process your request promptly. We will typically respond within one month after receiving all necessary details.

PROCESSING PROCEDURES
Below, we describe how we process personal data in various scenarios.

1. Access to Our Website
When you visit our website (the "Website") without using additional features or services beyond basic browsing, your browser and our hosting servers automatically exchange certain data.

DATA WE COLLECT

• Date and time of access

• Amount of data transmitted

• Browser type and version

• Operating system used

• IP address (potentially in anonymous form)
   

DATA TRANSFER

• Vendors: We may rely on reputable third-party hosting and content delivery services (e.g., Amazon Web Services). We have contractual agreements requiring these Vendors to process data only per our instructions and solely for the purposes of providing the Website.

• Authorized public authorities: We may disclose personal data if required by law enforcement, other government authorities, or to comply with legal obligations.

• Change in ownership: If the company is merged, sold, or reorganized, your data may transfer as part of that transaction in accordance with this Privacy Policy and applicable law.
   

LEGAL BASIS
Processing this data to display the Website to you is necessary to perform our contract with you (Art. 6(1)(b) GDPR). Once you stop browsing, we will cease actively processing this data; any logs are automatically deleted, typically within 24 hours.

SERVER LOG FILES
Whenever you access our Website, we automatically collect specific technical information stored in server log files. This helps us monitor the health of the Website, diagnose errors, and improve our services.

Data We Collect

• IP address

• Operating system version

• Configuration details of your device and browser

• Date and time of your Website use

This information is not combined with other data you provide us.

DATA TRANSFER

• Vendors: We may use trusted third-party services (e.g., Amazon Web Services, Google Cloud) for web hosting, backups, error tracking, fraud detection, and analytical support. We require these Vendors to process your data only per our instructions.

• Authorized public authorities: If required by law or legal process, we may disclose data to government agencies or our legal/tax advisors.

• Change in ownership: Data may be transferred in the event of a merger, sale, or reorganization, provided it is protected under the same level of data protection as outlined in this policy.
   

LEGAL BASIS
Server Log Files are processed under our legitimate interests (Art. 6(1)(f) GDPR) to administer and secure our Website and prevent fraud or unauthorized access. You may object if specific reasons relating to your situation override these interests.

DATA RETENTION
Server Log Files are generally retained for no longer than 90 days, unless an investigation into possible misuse, hacking attempts, or other security incidents requires a longer retention period.

3. Cookies
Cookies are small data files placed on your device to facilitate website functionality or improve user experience. They allow us or our Vendors to recognize returning visitors, remember preferences, and gather usage statistics.
We provide a cookie banner or settings where you can see and manage the specific cookies used on our Website. You can refuse or withdraw consent to cookies at any time through your browser settings or our cookie management tool.

4. Contact
You may contact us via email, phone, or other channels for general inquiries, legal or data protection queries, or to assert your rights under the GDPR.
Data We Collect

• Your contact details (e.g., name, phone number, email address)

• Information you voluntarily provide in your inquiry
   

DATA TRANSFER

• Vendors: We may use secure email hosting or customer support tools (e.g., Google Workspace). We contractually require these Vendors to use your data only as instructed.

• Authorized public authorities: If required by law or during legal proceedings, we may share relevant data with enforcement or regulatory authorities and our own legal/tax advisors.

• Change in ownership: Data may be transferred in the event of a corporate merger, acquisition, or reorganization.

LEGAL BASIS
Data processing for contact purposes is necessary for the performance of a contract or in order to respond to your request (Art. 6(1)(b) GDPR), and in some cases to comply with legal obligations (Art. 6(1)(c) GDPR).

DATA RETENTION
We delete your contact data once your request is fully resolved and there is no legal obligation to retain it further.

5. Analytics
We may use analytics tools to understand how you interact with our Website, improve content relevance, and enhance our services.

Data We Collect

• Your usage of the Website (e.g., pages viewed, click events)

• Technical information (e.g., approximate location, browser type)
   

DATA TRANSFER

• Vendors: We might use third-party analytics services (e.g., Google Analytics) under strict contractual instructions.

• Authorized public authorities: We may share necessary data to comply with legal obligations or authorities' requests.

• Change in ownership: Data may be transferred if Millerdale & Kingston Ventures is sold, merged, or reorganized, under the same commitments to data protection.
   

LEGAL BASIS
Your consent (Art. 6(1)(a) GDPR), obtained through our cookie banner or privacy settings, is the legal basis for these analytics. You may withdraw consent at any time.

DATA RETENTION
Analytics data is generally retained for up to 14 months, or until you opt out. You can opt out of analytics by adjusting your cookie settings or using the provided privacy controls on our Website.

6. Press Page and Newsletter
We may offer updates and news about Millerdale & Kingston Ventures and relevant developments (e.g., investment news, articles, industry insights) through a Newsletter or press updates.

Data We Collect

• Email address

• IP address (for subscription confirmation and security)
   

DATA TRANSFER
Authorized public authorities: If legally required or to protect our rights, we may share your data with regulatory bodies or law enforcement.

• Change in ownership: If we undergo a sale, merger, or acquisition, your data may be transferred subject to the same data protection obligations.
   

LEGAL BASIS
When you subscribe to our Newsletter, we rely on your consent (Art. 6(1)(a) GDPR). You can withdraw this consent anytime by unsubscribing.

DATA RETENTION
We will stop processing your data for the Newsletter once you unsubscribe, unless there is another valid legal basis or statutory retention requirement to keep it.

CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in the law or our data practices. When we make material changes, we will inform you accordingly (e.g., via a notice on our Website).

CONTACT US
If you have questions about this Privacy Policy or wish to exercise your rights, please contact:
Millerdale & Kingston Ventures Ltd
Georgiou Karaiskaki 11-13, Caris Salonica, Flat/Office 102, Pervolia, 7560, Larnaca, Cyprus
info@millerdalekingston.com
We appreciate your trust in us and are committed to handling your personal data responsibly in accordance with the GDPR and all other applicable regulations.