Date amended: 26th May 2020
- 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
We ask that you read this Policy carefully as it contains important information about what to expect when we collect your personal data and how we use your personal data. Your use of the Mintago Platform is also governed by our Terms and Conditions. Please ensure you read the Terms and Conditions as well as this Policy. By registering with the Mintago Platform, you agree to us collecting and utilising your data in accordance with this Policy. If you do not agree with this Policy, please do not use the Mintago Platform. Where we require your consent to comply with the Data Protection Act 1998 (“DP Law”), for example, for the transfer of data outside the EEA, we will ask for this separately.
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 email@example.com, or by writing to us at Mintago, 20 Guildford Road, Tunbridge Wells, TN1 1SW.
For the purposes of processing the personal data described in this Policy, we are the data controller (as defined in the Data Protection Act 1998).
We are registered with the Information Commissioner’s Office under number ZA555904
The data we hold on you
Information you may choose to give to us
We ask for and collect basic personal information as part of creating your user account with Mintago. You may also choose to provide us with additional personal information in order to obtain a better user experience when using the Mintago Platform. This additional information will be processed based on your consent.
- Information when creating a user account - When you sign up to the service and provide details such as your name, email, information on your identity document provided, selfie and address
- Additional profile information – You may choose to provide additional information as part of your Mintago profile (such as gender, age, income, interests, financial goals)
- Financial information – If you transact through the Mintago Platform, 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 – If you transaction through the Mintago Platform, 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
- Other information – You may otherwise choose to provide us information when you fill in a form, respond to surveys, post to community forums, participate in promotions, update or add information to your Mintago account, or use other features of the Mintago Platform
In addition to the Personal Data that we collect directly from you (as described above), we may also collect certain of your Personal Data from third party sources and combine that with information we collect through the Mintago Platform. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
- Your employer: The Mintago Platform is provided to you via your employer. As part of the provision of this service the employer would be required to share your name and contact information.
- Financial service providers: Certain features of the Mintago Platform would require your financial information held by third party financial service providers to be collected by Mintago, should you want to optimise the features being provided. You will be asked to provide explicit permission before this occurs.
- Third Party Services: If you link, connect, or login to your Mintago Account with a third party service (e.g. Google, Facebook), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
- Background Information: To the extent permitted by applicable laws, Mintago may obtain reports from public records of criminal convictions or sex offender registrations. For Members outside of the United Kingdom, to the extent permitted by applicable laws and with your consent where required, Mintago may obtain the local version of police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
- Other Sources: To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Mintago Platform through partnerships, or about your experiences and interactions from our partner ad networks.
Information we automatically collect from your use of the Mintago Platform
When you use the Mintago Platform, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Mintago Platform.
- Geo-location Information: When you use certain features of the Mintago Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Mintago may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
- Usage Information: We collect information about your interactions with the Mintago Platform such as the pages or content you view and other actions on the Mintago Platform.
- Log Data and Device Information: We automatically collect log data and device information when you access and use the Mintago Platform, even if you have not created a Mintago Account or logged in. That information includes, among other things: details about how you’ve used the Mintago Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Mintago Platform.
- Transaction Information: If you transact through the Mintago Platform, Mintago collects information related to your transactions through the Mintago Platform, including date and time, payment amount and other related transaction details. This information is necessary for Mintago being able to provide and improve the functionalities of the Mintago Platform to you.
How we use your data
We would 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.
- to maintain and improve the functionality of the Mintago Platform;
- to perform any contract we may have in place with you;
- to communicate with you including sending you notifications about your account;
- to allow us to manage your account you hold with us;
- to improve your user experience and to prevent abuse;
- for tax, risk management and other internal record keeping purposes;
- to respond to any questions or other matters raised by you in relation to us, the Mintago Platform or any of our products and services;
- to understand your use of the Mintago Platform, or keep a record of your product or service preferences;
- to provide you with information regarding our products and services, where you have consented to be contacted for such purposes or it is otherwise lawful for us to do so;
- for compliance with legal, regulatory and other good governance obligations; and
- for any other purposes related to the management of your legal relationship with us.
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, tailor the services that we provide you, and transfer your data to a third party, subject to your permission.
- 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
We may also convert your personal data into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve the Mintago Platform and/or our products and services.
Anonymised aggregated personal information does not personally identify you or any other user of the Mintago Platform and is therefore not personal data.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
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
- 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 (Amazon Web Services Cognito) 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. The data that we collect from you is stored on Amazon Web Services (AWS) servers within the European Economic Area (”EEA”).
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
On what legal basis do we process your data
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we have entered into an agreement with you or your organisation or any other contract to provide services to you.
We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to share your details with third parties not already included in our agreement with you or your organisation or any other agreement to provide services to you.
Our Legitimate Business Interests:
We have a number of lawful reasons that mean we can use your personal information, including your consent, where you give it. One lawful reason is something called ‘legitimate interests’. In general terms, “Legitimate Interests” means we can process your personal information if:
- We have a genuine and legitimate reason; and
- We are not harming any of your rights and interests.
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 firstname.lastname@example.org
How to make a complaint
If you would like to make a complaint, please contact us at: email@example.com. 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
We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We will update the date at the top of the Policy accordingly. We encourage you to check this Policy for changes when you revisit the Mintago website.