Mimeeq privacy policy

1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and users of the Mimeeq Software.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of those persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    In this policy, “we”, “us” and “our” refer to Mimeeq Sp. Z o.o (Mimeeq Spółka z ograniczoną odpowiedzialnością). For more information about us, see Section 15.

2. How we use your personal data

2.1    In this Section 2 we have set out:

(a)    the general categories of personal data that we may process;

(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

2.2    We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3    We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, financial transaction information and information contained in communications between us and you or your employer. The source of the customer relationship data is you, your employer, or in the case of transaction information our payment services providers. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, administering payments, keeping records and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

2.4    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.5    We may process information contained in or relating to any communication that you send to us or that we may send to you (excluding customer relationship data) (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The communication data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users and the proper administration of our website and business.

2.6    We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.7    We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.8    In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.9    Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1    We may disclose your personal data to Mimeeq Neal Bailey, a related business based in Poland.

3.2    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3    Your personal data held in our website database will be stored on the servers of our hosting services providers, Amazon Web Services, Inc. Usage data will be stored by our analytics services provider, Google, Inc. In addition, customer relationship data, communications data and notification data may be stored by our CRM and support infrastructure services providers, ConvertFox Global, Inc (trading as Gist). Finally, personal data in our website database may also be from time to time be processed by our appointed development services providers, xcactus (full name, xcactus spółka z ograniczoną odpowiedzialnością spółka komandytowa).

3.4    Financial transactions relating to our services may be handled by our payment services providers, currently Stripe, Inc. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the Stripe’s privacy policies and practices at https://stripe.com/gb/privacy.

3.5    In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. International transfers of your personal data

4.1    We have offices and facilities in the United Kingdom and Poland. To the extent that may be required by applicable law, transfers to each of these countries will be protected by appropriate safeguards, such as the use of standard data protection clauses adopted or approved by the competent data protection authorities.

4.2    Some of our services providers, including Google, Inc, are multi-national businesses with facilities around the world. We will ensure that international transfers to or by these businesses are protected by appropriate safeguards. These safeguards may include standard contractual clauses approved by the competent data protection authorities.

5. Retaining and deleting personal data

5.1    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.2    We will retain your personal data as follows:

(a)    usage data will be retained for a period of 36 months following the date of collection;

(b)    customer relationship data will be retained for a minimum period of 6 years following the termination of the relevant customer relationship, and for a maximum period of 7 years following that date;

(c)    notification data will be retained for a minimum period of 3 months following the date that we are instructed to cease sending the notifications, and for a maximum period of 12 months following that date (providing that we will retain notification data insofar as necessary to fulfil any request you make to actively suppress notifications); and

(d)    communication data will be retained for a minimum period of 6 years following the date of the communication in question, and for a maximum period of 7 years following that date.

5.3    Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Your rights

6.1    In this Section 6, we have listed the rights that you have under data protection law.

6.2    Your principal rights under data protection law are:

(a)    the right to access – you can ask for copies of your personal data;

(b)    the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)    the right to erasure – you can ask us to erase your personal data;

(d)    the right to restrict processing – you can ask use to restrict the processing of your personal data;

(e)    the right to object to processing – you can object to the processing of your personal data;

(f)    the right to data portability – you can ask that we transfer your personal data to another organisation or to you;

(g)    the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

(h)    the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

6.3    These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

6.4    You may exercise any of your rights in relation to your personal data by written notice to us.

7. Third party websites

7.1    Our website includes hyperlinks to, and details of, third party websites.

7.2    We have no control over, and are not responsible for, the privacy policies and practices of third parties.

8. Updating information

8.1    Please let us know if the personal information that we hold about you needs to be corrected or updated.

9. Acting as a data processor

9.1    In respect of user account data associated with the Mimeeq Software, we do not act as a data controller; instead, we act as a data processor.

9.2    Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

10. About cookies

10.1  A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

10.2  Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

10.3  Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

11. Cookies used on our website

11.1  We and our services providers use cookies set and read by our website for the following purposes:

(a)    authentication and status – we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website;

(b)    personalisation – we use cookies to store information about your preferences and to personalise our website for you;

(c)    security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(d)    analysis – we use cookies to help us to analyse the use and performance of our website and services; and

(e)    cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

12. Cookies used by our service providers

12.1  We use Google Analytics and Hotjar. These services providers gather information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy. And you can review Hotjar’s privacy policy at https://www.hotjar.com/legal/policies/privacy/.

12.2  We use Cloudflare to provide security and hosting-related services for our website which, again, use cookies.  You can see Cloudflare’s privacy policy at https://www.cloudflare.com/privacypolicy/.

13. Managing cookies

13.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647 (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

13.2  Blocking all cookies will have a negative impact upon the usability of many websites.

13.3  If you block cookies, you will not be able to use all the features on our website.

14. Amendments

14.1  We may update this policy from time to time by publishing a new version on our website.

14.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

15. Our details

15.1  This website is owned and operated by Mimeeq Sp.Zoo.

15.2  We are registered in Poland under registration number registration number KRS 0000841142 and our registered office is at Ulica Noskowskiego 2/1, Poznan, 61-704, Poland.

15.3  You can contact us:

(a)    by post, to the postal address given above;

(b)    using our website contact form; or

(c)    by telephone, on the contact number published on our website.