Privacy Policy
Effective Date: September 2024
1. Purpose
We are committed to protecting the privacy of your Personal Data at Mint Neurotechnologies Ltd.
The purpose of this Privacy Notice is to tell you how we handle your Personal Data, your privacy rights, and how the law protects you. It is important that you read this Privacy Notice so that you are fully aware of how and why we are using your data.
Mint Neurotechnologies Ltd is the controller and responsible for your personal data (collectively referred to as “MintNeuro”, "we", "us" or "our" in this privacy notice). For all data matters contact our Data Privacy Manager.
2. Contact Details
Full name of legal entity: Mint Neurotechnologies Ltd
Name of Data Privacy Manager: Dorian Haci
Email address: privacy@mintneuro.com
Postal address: 125 Wood Street, London, United Kingdom, EC2V 7AW
3. Website Third-Party Links
Websites, plug-ins, and applications from third parties may be linked on our website. Third parties may collect or share information about you if you click on those links or enable those connections. These third-party sites are not under our control and are not responsible for their privacy policies.
4. The type of personal information we collect
The different categories of Personal Data we collect and process about you are grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, title company or organisation details.
Contact Data includes home address, billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account, payment card details, and payroll data.
Transaction Data includes information about your payments to us and other details about products and services you have purchased from us, or we have purchased from you. Your shareholding or option holding will also be included if you are a shareholder or option holder.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Profile Data includes your username and password on our website, your preferences, and feedback and survey responses.
Usage Data includes information about how you use our website, intranet, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
As well as collecting and using individual data, we may also aggregate data such as statistical or demographic information. Despite being derived from your Personal Data, Aggregated Data is not considered Personal Data as it does not reveal your identity directly or indirectly. By aggregating your Usage Data, we can determine the percentage of users accessing a particular website feature. Regardless, if we combine Aggregated Data with your Personal Data and the combination can be directly or indirectly linked to you, we deem the combined data to be Personal Data for the purposes of this Privacy Notice.
5. How we get the personal information
Directly – Most of the personal information we process is provided to us directly by you. We may collect your Identity, Contact and Financial Data when you fill out forms or correspond with us via mail, phone, email, or otherwise. This includes personal data collected by us includes:
data provided upon application for our products or services;
data submitted when you subscribe to our newsletter;
data submitted when you request marketing materials be mailed to you;
data submitted when you give us some feedback;
data submitted when you apply for employment with us or when you become an employee.
Through automatic interactions – As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, and other similar technologies.
Through third parties or publicly available sources, we may receive categories of Personal Data about you from various third parties and public sources as set out below:
Technical Data from analytics providers such as Google; advertising networks and search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services, or from our registrars or nominated advisers.
Identity and Contact Data from data brokers, aggregators, or recruitment agencies.
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register.
6. How we use the personal information
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
Performance of Contract – Any time we need to perform a contract we are about to enter into or have entered into.
Legitimate Interest – It refers to the desire of our business to provide you with the best service/product and the safest experience possible. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Except for sending direct marketing communications to you via email or text message, we usually do not rely on consent as a legal basis for processing your Personal Data. Our consent to market to you can be withdrawn at any time by contacting us.
7. Purposes for which we will use your Personal Information
The table below provides a description, in table format, of all the ways we plan to use your Personal Data, and which legal basis we rely on to do so. Where appropriate, we have also identified our legitimate interests.
It is important to note that depending on the specific purpose for which you provide your Personal Data, we may process your data for more than one lawful ground. Where more than one legal ground is set out in the table below, please contact us for additional information about which legal ground we are using to process your Personal Data.
Purpose / Activity
To register you as a new client or employee.
To process and deliver your service or order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(c) As an employee
(d) As a shareholder or share option holder
To enable you to complete a survey.
To administer and protect our business and our intranet and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
To make suggestions and recommendations to you about goods or services that may be of interest to you.
Category of Personal Data
(a) Identity
(b) Contact
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communication
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Financial
(g) Transaction
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Identity
(b) Contact
(c) Profile
(d) Technical
(e) Usage
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
(a) Technical
(b) Usage
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Lawful basis for processing
Performance of a contract with you.
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
to recover debts due to us.
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests
to keep our records updated,
to study how customers and clients use our products/services; and,
to administer our employee relationships
to administer our shareholder and share option scheme relationships
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
to study how customers use our products/services; and
to develop them and grow our business.
(a) Necessary for our legitimate interests
for running our business and employee relationship,
provision of administration and IT services, network security,
to prevent fraud and
in the context of a business reorganisation or group restructuring exercise.
(b) Necessary to comply with a legal obligation
Necessary for our legitimate interests
to study how customers use our products/services;
to develop them;
to grow our business; and
to inform our marketing strategy.
Necessary for our legitimate interests
to define types of customers for our products and services;
to keep our website updated and relevant;
to develop our business; and,
to inform our marketing strategy.
Necessary for our legitimate interests
to develop our products/services; and
to grow our business
8. How we store your personal information
Your information is securely stored. To prevent your Personal Data from being accidentally lost, accessed or used unauthorisedly, altered or disclosed, we have implemented appropriate security measures. As a part of our Privacy Notice procedures, we will notify you and any applicable regulator if there is a suspected breach of Personal Data.
Our goal is to retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected, including for legal or accounting purposes. The retention period of Personal Data is determined by assessing the amount, nature, and sensitivity of the Personal Data, the potential danger from an unauthorised use or disclosure, the purposes for which we process your Personal Data, whether other means can be used to achieve those purposes, and any applicable legal requirements.
Your Personal Data may be anonymised (so that it cannot be used to identify you) for research or statistical purposes, in which case we may use it without further notification.
9. Your data protection rights
Under data protection law, you have rights including:
Your right of access: you have the right to ask us for copies of your personal information.
Your right to rectification: you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure: you have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing: you have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing: you have the right to object to the processing of your personal information in certain circumstances.
Your right to data portability: you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at privacy@mintneuro.com if you wish to make a request.
11. How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at privacy@mintneuro.com. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk