- Who we are
- The data we hold on you
- How we use your data
- Who we share your data with
- How we keep your data secure
- How long we store your data for
- Your rights & how to make a complaint
- Process for changing this policy and past versions
Who we are
We are Mintago Limited (“we”, “our”, “us”) and operate under the name of Mintago.
We’re committed to protecting and respecting your privacy. If you have any questions about your personal information please chat with us by emailing us at firstname.lastname@example.org, or by writing to us at Mintago, 8 Devonshire Square, London, EC2M 4PL.
We’re registered with the Information Commissioner’s Office under number ZA555904
The data we hold on you
The data we collect
- Information submitted through our app or website - For example, when you sign up to the app and provide details such as your name, email, information on your identity document provided, selfie and address, or other details we collect about how you use the app and website
- Financial information - For example, your bank sort code, account number or any other financial information that you provide us or give consent to us to access
- Details about your transactions with us - Any details about payments to and from you and other details of subscriptions and services you have purchased from us. Data in respect of your transactions with third parties
- Information from social networks or online accounts - Information from any accounts that you share with us
In addition to the Personal Data that we collect directly from you (as described above), we also collect certain of your Personal Data from third party sources:
- Data types collected: Identity data & contact information, Financial information
Financial services providers (with your permission)
- Data types collected: Financial information
How we use your data
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Account Creation and Transfer
- Data types used: Information submitted through our app or website
- Why we use it: To register you as a new user, and transfer your data to another employer, should you use our services with different employers from time to time.
- What is our legal basis: Performance of a contract with you
- Data types used: Information submitted through our app or website, Information on how you access our services, Details about your transactions with us
- Why we use it: To keep our website, our services and associated systems operational and secure. To keep your data and identity secure.
- What is our legal basis: We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks.
- Data types used: Information on how you access our services
- Why we use it: To track issues that might be occurring on our systems
- What is our legal basis: Performance of a contract with you so that we are able to monitor and ensure the proper operation of our platform and associated systems and services.
Optimisation and Analytics
- Data types used: Information submitted through our app or website, Financial information, Details about your transactions with us, Information on how you access our services, Information from social networks or online accounts
- Why we use it: To understand and measure how users use our Platform to improve it accordingly, and report relevant aggregated management information.
- What is our legal basis: We have a legitimate interest in ensuring the proper operation of, and improving, our services, website and associated IT services and networks.
Third party links
Who we share your data with
We may share your personal information with:
- Our employees (within Europe) - employees of Mintago when they need it to do their job.
- Your Employer(s) (within Europe) - to provide you the Mintago services
- Service Providers (Europe / US) - Our service providers provide us with IT and system services such as Know Your Customer (KYC) service providers
- Communication Partners (within Europe) - we use some third parties for communications, like e-mail, chat and phone, to provide you with the best customer service possible.
- Professional advisers (Europe / US) - Our lawyers, bankers, consultants, auditors and insurers
- HM Revenue & Customs, regulators and other authorities (within Europe) - Authorities may require reporting of processing activities in certain circumstances
We also collect, use and share “Aggregated Data”, which does not directly or indirectly reveal your identity.
How we keep your data secure
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Accounts will be password protected and this will be required each time the user logs in.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
How long we store your data for
We will only retain your personal data for so long as we reasonably need to use it for the purposes set out in 'How we use your data', unless a longer retention period is required by law (for example for regulatory purposes).
- Information submitted through our app or website, including details about your transactions with us and financial Data - identity information for as long as you remain a user of us and other information for as long as it is necessary to fulfil the purpose / use for which it is used
- Information on how you access our services - Three years from the date on which we collected or received it.
- Information from social networks or online account - Three years from the date on which we collected or received it
Your rights & how to make a complaint
By law you have the right to:
- Access the personal data we hold about you, or to get a copy of it.
- Make us correct inaccurate data.
- Ask us to delete, 'block' or suppress your data, though for legal reasons we might not always be able to do it.
- Object to us using your data for direct marketing and in certain circumstances ‘legitimate interests’, research and statistical reasons.
- Withdraw any consent you’ve previously given us.
- Request the transfer of your personal information to another party in certain formats, if practical
To do so, please email us on email@example.com
How to make a complaint
If you would like to make a complaint, please contact us at: firstname.lastname@example.org. We will reply to your complaint as soon as we can and do our best to fix the problem.
If you are still not happy, you can refer your compliant to our lead supervisory data protection authority, Information Commissioner’s Office (ICO).
Process for changing this policy and past versions
We’ll post any changes we make to our privacy notice on this page and, if they’re significant changes we’ll let you know by email.
None :) this is v1.0!