Personal Information
Last updated September 2, 2025
Introduction
Matviva respects the privacy rights of individuals and is committed to handling Personal Information responsibly, in accordance with applicable law, applicable contractual obligations, and Matviva’s Commitment to the Protection of Personal Information (the Commitment), described below. The Commitment sets out Matviva’s principles for the processing of Personal Information by and on behalf of Matviva.
The Commitment establishes a legal basis for cross-border transfers of Personal Information within the Matviva Group (all wholly or majority-owned divisions of Matviva Company and its subsidiaries), including where Matviva Group members adhere to relevant parts of the Commitment as data processors. Additionally, Matviva may carry out cross-border transfers of Personal Information to third parties outside the Matviva Group in accordance with applicable law. Matviva will handle Personal Information in accordance with the Commitment where applicable, unless in conflict with stricter requirements of local law, in which case local law will prevail.
Scope
The Commitment is designed to ensure that Personal Information will be protected regardless of geography or technology, when used within the Matviva Group, and applies to Matviva’s processing of Matviva Personal Information and Matviva Customer Personal Information.
Processing Personal Information
Matviva observes the following principles when processing Personal Information:
Fairness: Matviva will process Personal Information fairly and lawfully.
Purpose: Matviva will limit the processing of Personal Information to the fulfilment of Matviva’s specific, legitimate purposes. Matviva will only carry out processing that is compatible with such purposes unless Matviva, or its Customer where Matviva is a processor, has unambiguous consent for unrelated purposes.
In general, Matviva will process Personal Information:
- where Matviva has a legitimate interest that, on balance, justifies the processing;
- where necessary for the maintenance or the performance of a legal relationship between Matviva and the individual;
- where necessary for complying with an obligation imposed on Matviva by applicable law, regulation, or governmental authority;
- where there are exceptional situations that threaten the life, health or security of the individual or of another person;
- after obtaining the individual’s freely given, explicit and informed consent where required by applicable law;
- where the processing is in connection with a Customer service agreement.
Where consent has been obtained directly by Matviva, Matviva will provide a process to allow individuals to withdraw their consent to the extent required under applicable law, at any time and without charge.
Proportionality: Matviva will limit the processing of Personal Information to that which is adequate, relevant and not excessive in relation to the purposes for which Matviva collects and uses it.
Information Quality: Matviva will take reasonable steps to, and where Matviva is a processor provide Customers with a means to, ensure that Personal Information is accurate and kept up to date, to keep Personal Information only for as long as necessary for the purposes for which it is collected and used, and to delete or to render it anonymous after such retention requirements have been met.
Transparency: Where required by applicable law, Matviva will make available to individuals at the point of collection, or within a reasonable period of collection, information about Matviva’s identity; the purposes and legal basis of processing their Personal Information; intended recipients and cross-border data transfers; source(s) of Personal Information; how individuals may exercise their rights regarding Personal Information; contact details for the Data Protection Officer where applicable; and additional explanations as needed to ensure fair processing. Where Matviva collects Personal Information through the Internet or other electronic means, Matviva will post an easily accessible privacy notice that meets these transparency requirements.
Confidentiality: Matviva will maintain the confidentiality of Personal Information it processes, except where disclosure is required by an applicable operational or legal requirement. This obligation will continue even after the relationship with the individual, or Customer where Matviva is a processor, has ended.
Security: Matviva strives to protect Personal Information with appropriate technical and organizational measures to ensure its integrity, confidentiality, security and availability. Matviva will inform individuals of a security breach affecting their Matviva Personal Information that could pose a high risk to their individual rights and freedoms. In accordance with applicable law, Matviva will provide reasonable assistance to Customers, where Matviva is a processor, to ensure the security of their processing and will inform Matviva Customers of a security breach of Matviva Customer Personal Information as required under such laws.
Sharing and/or Transferring Personal Information
Matviva may share or transfer Personal Information in the following circumstances:
- Personal Information may be shared within the Matviva Group for the purposes specified above, provided the Matviva Group entity processing Personal Information adheres to this Commitment.
- Matviva may provide Personal Information to selected suppliers or service providers hired to perform certain processing or other services on its behalf. Matviva will strive to ensure that new supplier engagements provide for processing of Personal Information in a manner consistent with this Commitment and applicable law by means of a legal relationship established through a contract or other legally permissible means. Under such contracts, suppliers must implement adequate security measures and may only process Personal Information in accordance with Matviva’s instructions.
- Matviva may disclose certain Personal Information to other third parties where required by law, to protect Matviva’s legal rights, or in connection with any Matviva merger or acquisition activity or the insolvency or re-organization of any part of Matviva.
Processing of Sensitive Personal Information
Where Matviva processes and/or transfers Sensitive Personal Information Matviva will inform the individual of the processing and/or transfer and obtain explicit consent for such processing and/or transfer when Matviva is required to do so by applicable law. Appropriate security measures will be provided depending upon the nature of this information and the risks associated with its intended uses.
Accountability
Matviva is accountable for fulfilling the requirements sets out in the Commitment and under applicable law. In particular, Matviva will:
- take the necessary measures to observe the requirements of the Commitment and applicable law; and
- have the necessary internal mechanisms in place to demonstrate such observance, including maintaining a record of its processing activities in accordance with applicable law.
Privacy Program
Matviva employs privacy practices designed to support its compliance with the Commitment and applicable law, including the appointment of a network of privacy leaders, education and awareness programs, incident response protocols, privacy impact assessments, audit routines and a Privacy by Design approach to process and system development.
Individual Rights
In accordance with applicable law, an individual who has satisfactorily established his or her identity to Matviva may exercise the following rights in relation to Personal Information Matviva has collected directly from him or her; where Matviva is a processor, Matviva will assist the Customer in meeting its privacy obligations toward individuals:
Access: Where required by applicable law, Matviva will provide an individual Personal Information about him or her that Matviva holds, including information concerning the source of the Personal Information, the purposes of any processing by Matviva and the recipients, or categories of recipients, to whom such Personal Information is disclosed.
Correction and Deletion: Valid requests for correction or deletion of Personal Information which is incomplete, inaccurate or excessive will be respected, and confirmed as such, except that deletion will not be performed where retention is required by the contractual relationship between Matviva and the individual, in the context of a legal dispute or other legal retention requirement, or as otherwise required by applicable law.
Objection: Matviva will cease processing Personal Information where an individual’s objection is justified under applicable law, for example where the individual’s life or health is at risk due to the processing. An individual also has the right to object to decisions based solely on automated processing of Personal Information that produce legal effects which significantly affect the individual involved, except where the individual requested the processing, or when necessary for the legal relationship between Matviva and the individual. In the latter case, the individual may give his or her views on the automated decision. An individual has the right to object to processing of Personal Information by Matviva for marketing purposes where allowed by applicable law. The exercise of this right to object may be superseded where Matviva can demonstrate that its compelling legitimate interest in continuing the processing overrides the interests or fundamental rights and freedoms of the individual.
Restriction: An individual also has the right to request the restriction of any processing of his or her Matviva Personal Information by Matviva, to the extent such right is provided for under applicable law, for example where the accuracy of the Matviva Personal Information is contested. Matviva will cease processing such information where the restriction is justified, with the exception of storage and other permitted continued processing under applicable law.
Complaints: Any individual who claims to have suffered damage as a result of non-compliance by a Matviva Group entity with the Commitment may file a complaint with the applicable Matviva Data Protection Officer, or with Matviva’s Complaint Handling Processes available on Matviva’s websites if other channels are unavailable or exhausted:
Contact us
If you have questions regarding our handling of your Personal Information and would like to lodge a complaint, or wish to contact our Data Protection Officer, please contact us using the contact information listed below. We will promptly address your concern and strive to reach a satisfactory resolution.
Email:
m.privacy@matviva.com
251-418-0006
Attn: Data Protection Officer
Enforcement: An individual who has suffered damage as a result of a breach of the Commitment may be entitled to receive compensation for such damages in accordance with applicable law and as provided in the Commitment. An individual who is entitled to receive compensation may enforce his or her rights as provided in the Commitment by direct recourse to the courts or other judicial authority in accordance with applicable law.
Cooperation with Supervisory Authorities
Matviva will cooperate with any competent national or regional supervisory authority responsible for supervising applicable privacy law that has good cause to question any processing of Personal Information by Matviva, and will comply with such competent supervisory authority’s decisions on any issue related to the Commitment.
Changes to the Commitment
Matviva reserves the right to modify the Commitment. Any material changes will be submitted to Matviva’s lead Data Protection Authority and/or its trustmark agent, where appropriate, and will be notified on Matviva’s website.
Definitions
Personal Information is any information relating to an identified or identifiable natural person.
Matviva Personal Information is any Personal Information that is obtained in the context of an individual’s relationship with Matviva and which Matviva processes for its own purposes. Such Matviva Personal Information may include, for example, employment data obtained in the context of an employment relationship with Matviva, customer data obtained in the context of a customer relationship with Matviva and supplier data obtained from Matviva’s suppliers.
Matviva Customer Personal Information is any Personal Information that is obtained in the context of the provision of services by Matviva to a Customer under a service agreement and which Matviva processes on behalf of the Customer.
Customer is a person or entity that enters into a service agreement with Matviva.
Sensitive Personal Information, a special category of Personal Information, is information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health, sex life or sexual orientation.