Mindstone Learning Limited (“Mindstone”, "we", "our", or "us") is committed to protecting and respecting your privacy.

 

1. OUR APPROACH TO PRIVACY

This privacy policy sets out how we collect, use and share data that identifies or is associated with you ("personal information") as a result of you using our website at https://www.mindstone.com/ or the Mindstone App (together, the "Site") or otherwise interacting with us (whether online or offline).

 

2. ABOUT US

Mindstone Learning Limited is a limited liability company incorporated in England and Wales with company number 12535319 and having its registered address at Capital House, 61 Amhurst Road, London, England, E8 1LL.

Mindstone is the data controller of the personal information we hold about you. Our ICO Registration Number is ZB007467.

If you have any questions about this policy or our approach to privacy you can contact us as follows:

By email: privacy@mindstone.com

By post:

Mindstone Learning Limited

Capital house

61 Amhurst Road

London

E8 1LL

 

3.PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

The table at Annex 1 sets out the categories of personal information we collect about you and the purposes for which we use that information. The table also lists the legal bases which we rely on to process your personal information.

More generally, we:

  • collect personal information that you voluntarily submit to us, such as your name and contact details, when you request access to our services, or otherwise interact with us;

 

  • may require you to provide certain personal information in order for us to provide you with our services; and

 

  • automatically collect personal information indirectly about how you access and use the Site (such as the pages you visit), as well as information about the device you use to access the Site.

 

We use this information to correspond with you, perform our agreements with you, carry out marketing activities and our other day-to-day business activities and operations.

We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

We will indicate to you where the provision of certain personal information is required in order for us to provide you with certain features of the Site. If you choose not to provide such personal information, we may not be able to provide you with access to certain aspects of the Site.

 

4. ANONYMOUS DATA

We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Sites and developing new products and features. We may also share such anonymised information with others.

 

5. DATA RETENTION

We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 [INSERT LINK] in accordance with our legal obligations and legitimate business interests.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Note that you can delete your account at any time. If you choose to do so, this will remove your account page from our systems and our related software. We guarantee this will delete all stored data.

 

6. RECIPIENTS OF PERSONAL INFORMATION

We may also share your personal information with the following (as required in accordance with the uses set out in Annex 1 [INSERT LINK]):

  • Service providers: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing data hosting, customer relationship management and analytics services.
  • Professional advisors: we may share your personal information with our advisors, including our lawyers, accountants and insurers.
  • Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
  • Law enforcement, regulators, governmental authorities and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with financial or tax reporting obligations; (ii) comply with the law and the reasonable requests of law enforcement; (iii) detect and investigate illegal activities and breaches of agreements; and/or (iv) exercise or protect the rights, property, or personal safety of Mindstone or others.
  • Other members of the Mindstone group: we may share your personal information with our affiliates (for example, where they provide services on our behalf) or where such sharing is otherwise necessary in accordance with the uses set out in Annex 1.

In addition, we may share your personal information with other third parties if you have provided your consent for us to do so.

 

7. MARKETING AND ADVERTISING

From time to time we may contact you with information about Mindstone, including for the purposes of sending you marketing messages and asking for your feedback.

Most marketing messages (including newsletters) we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

We will only send you marketing messages if you have given us your consent to do so, unless consent is not required under applicable law (e.g. in certain circumstances where we have a pre-existing customer relationship with you).

You can withdraw your consent or opt out of receiving further communications at a later date by clicking on the unsubscribe link at the bottom of our marketing emails.

8. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

Security. We implement a variety of security measures to ensure the security of your personal information on our systems, including regular security scanning of our systems and external security audits. Any personal information collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your personal information or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure.

International Transfers of your Personal Information. If you are located in the United Kingdom (“UK”) or European Economic Area (“EEA”), we may transfer your personal information to countries outside of the UK and the EEA, for example, to third party service providers located in third countries. In some cases, this might result in your personal information being transferred to a country not recognised as having an adequate level of protection for personal information. These international transfers of your personal information will be made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the UK government or the European Commission. If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this privacy policy.

 

9. YOUR RIGHTS

You have the following rights in respect of your personal information that we hold under applicable privacy law:

  • Right of access. You have the right to obtain access to your personal information.
  • Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
  • Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
  • Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
  • Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
  • Right to object. You have a right to object to the processing we carry out on the basis of legitimate interests in certain circumstances. You can also object to our direct marketing activities for any reason by clicking the "unsubscribe" link set out in any marketing communication or contacting us using the details set out above.
  • Right to withdraw consent. If you have provided consent to any processing of your personal information, you have a right to withdraw that consent.

Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.

If you wish to exercise one of these rights, please contact us using the contact details set out above. For security purposes, we may require you to verify your identity before we comply with your request.

If you are in the UK or EEA, you also have the right to lodge a complaint to your national data protection authority. The relevant data protection authority in the UK is the Information Commissioner's Office ("ICO"). Information on how to make a complaint to the ICO is available at www.ico.org.uk. If you are resident in the EEA, you can find details regarding your local data protection regulator here.

Californian Residents Only

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to privacy@mindstone.com.

 

10. COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar technologies on the Site for various purposes, including improving your experience of the Site. For more information about cookies and why we use these, please refer to our Cookies Policy [insert link].

 

11. LINKS TO THIRD PARTY SITES

The Site may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

 

12. CHILDREN

The Site is not intended for or directed at children under the age of 13 years and we do not knowingly collect information relating to children under this age.

 

13.CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

This privacy policy was last modified on the 27th July 2021.

 

ANNEX 1 – PERSONAL INFORMATION WE COLLECT

Category of personal information

How we use it

Legal basis for processing

 

Contact details (such as email address and phone number), account details (such as username and password)

To register you with Mindstone

Performance of a contract

 

Administration of account (including sending you information regarding changes to our policies, other terms and other administrative information).

 

Performance of a contract

 

Profile data (such as your content), search history (such as online search history and interactions with content), interaction history (such as interactions between users), account details (such as username and password)

 

To provide you with our services (including displaying your content to you and allowing you to interact with other users).

Performance of a contract

 

Contact details (such as email address), technical information (such as browser type, IP address etc.), account details (such as username and password)

Provision of customer support and to administer the Site (including troubleshooting and resolving technical issues).

It is necessary in our legitimate interests, namely to ensure we are able to resolve any issues you have in accessing the Site or using our services.

For operational reasons, such as improving efficiency, training and quality control.

 

It is in our legitimate interests to be as efficient as we can so we deliver the best service for you.

Contact details (such as email address), marketing and communications data (such as marketing consents and other information you provide us)

Marketing and advertising (including sending you newsletters and measuring the effectiveness of our marketing).

 

Consent (if required under applicable law).

 

If consent is not required under applicable law, such processing is necessary in our legitimate interests to develop and grow our business.

 

You have the right to opt out of receiving direct marketing communications from us at any time by contacting us at privacy@mindstone.com or using the “unsubscribe” link in emails.

 

To respond to queries and complaints and provide you with information and materials that you request from us.

 

It is necessary in our legitimate interests to respond to your queries and provide any information and materials requested in order to generate and develop business.

 

Technical information (such as browser type, IP address etc.) and usage data (pages you viewed and searched for, length of visits to certain pages etc.)

 

To administer the Site, including resolving technical issues, troubleshooting, data analysis, testing and research and statistical purposes.

 

It is in our legitimate interests to monitor Humanity to ensure that it functions properly and is secure.

 

To ascertain your preferences and improve the Site to ensure that content is presented in the most effective manner for you.

 

Consent

Analytics

Consent

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