Last updated: 16.02.2022
This Privacy Notice describes how mnAI Data Solutions Limited (referred to as either “mnAI”, “We”, “Us” or “Our”) collects, uses and discloses Personal Data relating to:
- visitors and users of the Website and individuals at mnAI’s Clients (collectively “Users”); and
- shareholders and directors of UK companies (“Shareholders / Directors”) whose Personal Data, on request of mnAI’s Clients, may be processed in the context of mnAI’s Services and Reports.
Collectively, we refer to Users and Shareholders / Directors as You throughout this Notice, though there are some sections which relate solely to either Users or Shareholders / Directors, and we have identified those by using those specific terms.
mnAI (The Beehive, City Place, Gatwick, RH6 0PA) is the data controller of Personal Data processed under this Privacy Notice.
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions.
The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
For the purposes of this Privacy Notice:
- Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- Account means a unique account created for Users to access our Website or parts of our Website.
- Client(s) means a company that engages mnAI for mnAI’s Services and Reports.
- Website refers to mnAI, accessible from https://www.mnai.tech
- Service collectively refers to provision of the Website and the processing of personal data on request of mnAI’s clients for provision of mnAI’s Services and Reports.
- mnAI’s Services and Reports means the service provided by mnAI to its clients on request.
- Service Provider means any natural or legal person who processes the data on behalf of mnAI. It refers to third-party companies or individuals employed by mnAI to facilitate the Service, to provide the Service on behalf of mnAI, to perform services related to the Service or to assist mnAI in analyzing how the Service is used.
- Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
- Personal Data is any information that relates to an identified or identifiable individual.
Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
- Usage Data refers to data collected automatically, either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit).
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data you provide
While using Our Website, We may ask You to provide Us with certain Personal Data that can be used to contact or identify You. Such Personal Data may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Bank account information in order to pay for products and/or services on the Website
- Usage Data (as set out in more detail below)
When You pay for a product and/or a service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:
- Date of birth
- Passport or National ID card
- Bank card statement
- Other information linking You to an address
Personal Data relating to Shareholders / Directors
For Shareholders / Directors whose Personal Data is processed on request by a Client, We may process the following Personal Data:
- First name, any given middle name and last name, which is obtained from publically available sources; and
- Assumed ethnicity tag which indicates a probability of a particular Director being from an ethnic minority background, and which is obtained from searches of a third party database.
Note that we will not share any such individual assumed ethnicity, but instead provide Clients (on request) with a company-level tag indicating (where relevant) that a majority of the Directors in that company are assumed to be from an ethnic minority background.
Usage Data is collected automatically when using the Website.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Website by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Website or when You access the Website by or through a mobile device.
Tracking Technologies and Cookies
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
You can instruct Your browser to refuse all cookies or to indicate when a cookie is being sent. However, if You do not accept cookies, You may not be able to use some parts of our Website.
Cookies can be “Persistent” or “Session” cookies. Persistent cookies remain on your personal computer or mobile device when You go offline, while Session cookies are deleted as soon as You close your web browser. Learn more about cookies: All About Cookies.
We use both session and persistent cookies. For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.
Use of Your Personal Data
mnAI may use Personal Data collected via the Website for the following purposes:
- To manage Your Account: to manage Your registration as a user of the Website or mnAI’s Services and Reports. The Personal Data You provide can give You access to different functionalities of the Website that are available to You as a registered user.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Website or otherwise.
- To contact You: To contact You by email, telephone, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information. We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us. We may use Email Marketing Service Providers to manage and send emails to You, including MailChimp.
- To manage Your requests: To attend and manage Your requests to Us.
mnAI may use Personal Data collected on Directors for the following purposes:
- To assign a company level tag relating to the assumed ethnicity of the Directors collectively – which will be “assumed ethnic minority led” (where a majority of Directors are highly likely to be from an ethnic minority background).
- To provide that company-level tag to our Clients, who must first confirm that they will only use it in order to identify or keep under review the existence or absence of equality of opportunity or treatment between groups of people of a particular racial or ethnic origin, with a view to enabling such equality to be promoted or maintained.
Sharing and Disclosure of Your Personal Data
For Users, We may share/disclose your Personal Data in the following situations:
- With Business partners: We may share Your Personal Data with Our business partners to offer You certain products, services or promotions.
- With other users: when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
For Shareholders / Directors, We may share your Personal Data in the following situations:
- With Clients: on request by a Client, we will share the company-wide assumed ethnicity tags described above, but only on an aggregate basis at company level and which does not specifically identify any individual Shareholders / Directors by name.
For both Users and Shareholders / Directors, We may share your Personal Data in the following situations:
- With Service Providers: We may share Your Personal Data with Service Providers to assist us in providing the Service. For Users this may include to monitor and analyse the use of our Website, for payment processing, to contact You.
- For Business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Our assets, financing, or acquisition of all or a portion of our business to another company.
- With Affiliates: We may share Your information with Our Affiliates, in which case we will require those Affiliates to honour this Privacy Notice. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
- Law enforcement: Under certain circumstances, We may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements: We may disclose Your Personal Data in the good faith belief that such action is necessary to: comply with a legal obligation; protect and defend the rights or property of mnAI; prevent or investigate possible wrongdoing in connection with the Service; protect the personal safety of You or the public; protect against legal liability.
Retention of Your Personal Data
mnAI will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Website, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at mnAI’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers in a country which is different to the country in which You are located and where the data protection laws may differ.
mnAI will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Notice and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your Personal Data.
Security of Your Personal Data
The security of Your Personal Data is important to Us. We use appropriate technical and organisational measures to protect Your Personal Data. The measures We use are designed to provide a level of security appropriate to the risk of processing Your Personal Data.
Detailed Information on the Processing of Your Personal Data
Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.
We may provide paid products and/or services on the Website or otherwise in connection with mnAI’s Services and Reports. In that case, we may use third-party services for payment processing (e.g. payment processors).
When You use our Website to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.
Legal Basis for Processing Personal Data
Our legal basis for collecting and using the Personal Data described within this Privacy Notice will depend on the Personal Data concerned and the specific context in which We collect it.
However, We will normally collect Personal Data from You only where We need the Personal Data to perform a contract with You, where the processing is in Our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms, or where You have given Your consent to the processing. In some cases, We may also have a legal obligation to collect and process Your Personal Data, or may otherwise process the Personal Data in the public interest or where it is necessary in order to protect Your vital interests or those of another person.
Where mnAI processes special category personal data (specifically, assumed ethnicity of Shareholders / Directors) this is on the basis of substantial public interest and in particular the equality of opportunity or treatment condition, as permitted under the UK Data Protection Act 2018.
In any case, mnAI will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. For more information, please contact us using the details within this Privacy Notice.
Your Data Protection Rights
mnAI undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
You have the right under this Privacy Notice, to:
- Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
- Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
- Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
- Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
- Complain to a Data Protection Authority. You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data.
- Shareholders / Directors also have the right to give notice to mnAI (using the contact details below) requiring Us not to process Your assumed ethnicity data. We will stop processing Your assumed ethnicity data within a reasonable period of receiving such notice.
You may exercise any of Your data protection rights by contacting us using the details in this Privacy Notice.
Our Service does not address anyone under the age of 13. We do not knowingly collect Personal Data from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes to this Privacy Notice
We may update Our Privacy Notice from time to time in response to changing legal, technical or business developments. When We update Our Privacy Notice, We will take appropriate measures to inform You, consistent with the significance of the changes We make. You can see when this Privacy Notice was last updated by checking the “Last updated” date at the top of this Privacy Notice.
If you have any questions about this Privacy Notice, You can contact us:
- By email: email@example.com