WHO WE ARE
We are Ponder Solutions Limited (registered in England and Wales with company number 08255059) trading as MT4 Ninja and our address is 25 Durweston Close, Bournemouth, BH9 3QB, United Kingdom (referred to as “we” or “us” or “our”). We are the providers of the website mt4ninja.com (referred to as the “Site” or “Website”, “MT4 Ninja”). We are also the data controller and operator of mt4ninja.com
We treat data protection with the highest priority. We are registered with the Information Commissioners Office (ICO) Registration reference: ZA773357.
A reference to “you” or “your” is a reference to a user of the Site or any of our services.
- the MT4 Ninja website at mt4ninja.com
- social media or official MT4 Ninja content on other websites;
- our mobile devices and Applications (“Apps”)
It also relates to our use of any personal information you provide to us by phone, SMS, email, in letters and other correspondence and in person.
OUR PRIVACY PROMISE
Ponder Solutions Limited (“mt4ninja.com“, “MT4 Ninja”, “we”, “us”, “our”) is committed to protecting your personal information, being transparent about the data we hold and wherever possible giving you control over how we use it.
It’s important that you read this policy to understand the information we may hold about you, how we use it and how you can access or update your information, modify your preferences or request deletion of your personal data.
- What information we collect about you;
- How we collect and use information about you;
- Whether we disclose your details to anyone else;
- The choices available to you regarding the personal information you provide to us;
- When and how your data may be shared with third parties.
Amendments and updates to this Policy may be made from time to time. Any revisions will be posted on this page so you will always be aware of the information we collect. Please review this page regularly so that you are aware of any changes.
WHAT PERSONAL DATA WE COLLECT AND WHY WE COLLECT IT
Personal data is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We collect personal information from you when you use our Services.
We collect personal information from you and any devices (including mobile devices) you use when you: use our Services, register for an account with us, provide us information on a web form, update or add information to your account, participate in community discussions, chats, or dispute resolution or when you otherwise correspond with us.
Some of this personal information, such as a way to identify you, is necessary to enter into our Terms and Conditions. The provision of all other personal information is voluntary, but may be necessary in order to use our Services, such as the offer details or contact information needed to post an ad.
INFORMATION YOU PROVIDE WHEN YOU PURCHASE A PRODUCT ON THE WEBSITE
As part of the purchase process on the Website, depending on the services you choose, we may collect your name, telephone number, addresses and email address as well as details of the property you wish to sell and your IP address.
- We use your name and email address to register your account and fulfil your order, confirm that your order has been fulfilled and send you service communications about how to access and manage your account and use the product purchased.
- If you choose to access a particular feature or to fill in a form on the Site you may be asked to provide information about yourself, such as your name and contact details. We may also collect other information about you that you provide.
- Information that you provide to us when you register as an MT4 Ninja user.
- We may also use the information you provide for internal business records and purposes, including to analyse and develop our products and services and the Website
- Your email address or any other information about you is never displayed on our Website.
You may be required to supply payment card details to complete your purchase. We use third party payment providers to manage online card payment transactions. Payment card information is collected over a secure online payment gateway provided by:
All payment transactions processed are encrypted by our payment providers. Your payment card information is used solely to process payment for your advert. We do not receive and retain record of your payment card details.
- We also collect information that you provide to us by corresponding with us by phone, e-mail or otherwise.
INFORMATION YOU PROVIDE WHEN YOU BROWSE OR USE SERVICES ON THE WEBSITE
To make a purchase or use certain additional services, we will collect your email address and name.
When you use the Website we will also collect your IP address.
HOW WE USE THE INFORMATION WE COLLECT
We use the information we collect to:
- provide and administer the Website and related services and manage internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to develop the Website and our products and services.
- to make sure that you receive the benefit of the MT4 Ninja service.
- to provide the Website to you.
- to enhance the services that you select on our Site.
- to process any queries that you have about MT4 Ninja or its members.
- to customise and enrich your experience on our Site.
- to deliver relevant advertising to you whilst you are on the Site.
- generate an overall audience profile of visitors using the Website. We use this information to assist us in developing relevant content on the Website.
- provide customers who have opted-in to receive marketing communications, with relevant and timely offers by email.
- identify the location of visitors, to block disruptive or fraudulent use, to establish the number of visits from different countries.
- to process and resolve any queries that you may have
LAWFUL BASIS WE USE TO PROCESS YOUR INFORMATION
We process your data based on the lawful bases set out below. We may process information you provide based on more than one lawful ground depending on the specific purpose for which we are using it:
- Contract: To enter into a contract with you and fulfil our contractual obligations to you. This processing is necessary for us to provide the service you have requested including registering and managing your account and providing service updates and our support services.
- Consent: To provide information and take actions in relation to services which you have opted-in to receive. This includes where you specifically request for your details to be passed onto a third party or where you opt-in to receive relevant marketing communications from us (e.g. industry news and offers).
- Legal Obligation: Where processing is necessary to comply with legal or statutory requirements on us. This may include cooperating with police in relation to their investigations.
- Legitimate interest: To improve our Website, products and/or services, understand how visitors and customers use our Website, products and/or services, undertake market research and inform our general marketing, to run our business and maintain the security or our Website and services for you, us and other Website visitors and customers.
- to provide data services to third parties such as banks, building societies, insurance companies and other financial institutions so that they can process this property data for their purposes, including using the data in services such as property valuation models or surveyor comparison software.
Where consent is required for us to process certain types of your personal data, it must be clearly given. You may give us your consent to receive our marketing communications and/or when you use the Website to request services provided by dealers.
Where you have given consent for MT4 Ninja to process your personal data you may withdraw consent at any time by contacting us. We will cease processing your data based on that consent but this does not affect any processing we have undertaken at any time before withdrawal.
If you have given consent for your details to be passed to a third party your data may already have been used by them to respond to your request before we can action your consent withdrawal. In this event, you will need to contact them to withdraw your consent to their use of your personal data.
DISCLOSURE OF YOUR INFORMATION
MT4 Ninja will not pass on your personal data to third parties except as set out in this policy or with your consent. We may disclose your personal information to third parties for the following purpose(s) and in the following circumstances as part of our processing activities:
- We will send your personal information to our partners to enable them to provide you with the services and products that you have requested or consented to receive details of via the Website. In certain circumstances, some of our partners may subsequently transfer, process and store your personal information outside of the European Economic Area (“EEA”) for their business and administration purposes, in accordance with their own privacy policies. If you have queries or require more information on how these third parties use information, including transfers outside of the EEA, please read their privacy policies or contact them.
- We may use service providers to help us run the Website or services available on the Website, some of whom may be based outside the EEA. Some of our webpages use plugins from third party platforms (such as the ‘Facebook Recommend’ or Facebook Gestures’ function). Information about your visit to the Website may be collected by these third party providers on these pages. If you browse these pages whilst still also logged in to your account on the third party platform, information collected by the third party may be connected to your account on the third party platform. If you have queries or require more information on how these third parties use information, including transfers outside of the EEA, please read their privacy policies or contact them.
- Where we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce our Terms and Conditions and any other agreements.
- If we sell or buy any business or assets, in which case MT4 Ninja may disclose your personal data to the prospective seller or buyer of such business or assets.
- If we or substantially all of our assets are acquired by a third party, personal data held by us about our customers may be disclosed to the prospective buyer.
- We may share your personal information with our group companies.
- We may share any information that we collect with parties including: our legal and professional advisors, the police, other public or private sector agencies, governmental or representative bodies (which may include insurance companies, finance companies and/or other agencies) in accordance with the relevant legislation for the purposes of the prevention or detection of offences, and/or the apprehension or prosecution of offenders.
- We are not responsible for any use of your personal data by these parties except where they act as our processor.
- We retain access to all personal information that we have collected from you or about you. Once your information has been passed to one of our members in the course of providing our services (most typically when you communicate with a property seller through our Website) then that MT4 Ninja member will have a copy of the information that you have provided within your enquiry and your contact details which they will use to get in touch with you. In relation to property data, it is provided to us by our members (or third parties that act on their behalf). Our members (or any third party that acts on their behalf) will be responsible for information in their possession and that information will be subject to any privacy terms or policies that the member has in place; we are not responsible for use (or misuse) of your information by any of our members.
- When our service is available via the websites of our partners, those partners may have access to your information. We may also have links to other websites from our Website. We are not responsible for the content, security, privacy policies and practices of any other websites, even if you access them using links from this Website or if you can access this Site or use our services from them. We recommend that you check the policy of each website that you visit and make sure that you are comfortable with the terms of such policies before providing any personal information.
- We will not otherwise disclose, sell or distribute your information to any third party without your permission unless we are required to do so by law or to obtain professional advice.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored securely within the EU, and not transferred outside the EEA unless specifically detailed.
Payment card information, details you provide when requesting third party services through the Website is handled in accordance with the relevant service providers’ privacy policies and may be transferred and stored or processed by them outside of the EEA in accordance with their privacy policies. Where we transfer your data outside of the EEA, we will ensure that safeguards are in place to provide similar degree of protection is available to protect it. This may include contractual protections in place with our service providers or transferring your data to countries or parties which are recognised as providing suitable protection by the European Commission.
Certain parties to whom we disclose your personal data may transfer your data outside of the EEA after we disclose it to them as part of their business and administration activities (see above, Disclosure of your information). We are not responsible for any use of your personal data by these parties except where they act as our processor. If you have queries or require more information on how these third parties use your information, including such transfers outside of the EEA, please read their privacy policies or contact them.
MT4 Ninja uses strict procedures and security features designed to prevent any unauthorised access to your data that we hold.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Only employees who need access to your information to perform a specific job are granted access to personally identifiable information. We may require you to co-operate with our security checks before we disclose information to you. If you are a registered user, you can update the personal information that you give us at any time by viewing your My Account page.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
MT4 Ninja will process personal data for as long as necessary to fulfil the purpose we collected it for, including the purpose of legal, accounting and reporting requirements, and for as long as necessary for the prevention and detection of criminal activity. The period for which we process and store the personal data for varies depending on the use you make of the Website and the products and/or services we offer. Where you register an account or place an advert we will retain your data for as long as your account and/or advert is live and a period after your account is closed or advert ends to enable us to satisfy our legal, accounting and reporting requirements.
In some circumstances you can ask us to delete your data: see Right to be forgotten below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR RIGHTS AS A DATA SUBJECT
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you. In the event that MT4 Ninja refuses your request under rights of access, we will provide you with a reason as to why
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – in certain circumstances you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing, automated processing or profiling.
- Right to complain to the supervisory authority – you have the right to complain as outlined below.
If you wish to make a complaint about how your personal data is being processed by MT4 Ninja (or third parties as described above), or how your complaint has been handled, in the first instance please let us know your concerns by contacting us. You also have the right to lodge a complaint directly with the UK supervisory authority which is the Information Commissioner’s Office and can be contacted via the details at www.ico.org.uk.
If you have any questions regarding the use of your personal data please contacting us using our contact form or write to us:
Ponder Solutions Limited, 25 Durweston Close, Bournemouth, BH9 3QB, United Kingdom
COOKIES AND TRACKING
Any changes we may make to this Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this Policy.