Privacy Policy

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 85 Great Portland Street, London, England, W1W 7LT

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
85 Great Portland Street
London
W1W 7LT

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 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 :

• 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.

• Sponsors and partners: As part of our commitment to providing valuable experiences at our events, we may share certain personal data, such as email addresses and information about event attendees, with our sponsors and partners. This data sharing enables sponsors and partners to reach out to you with relevant offers, updates, and promotions related to the event. By agreeing to our privacy policy and providing your consent, you acknowledge that your personal data may be shared with our event sponsors and partners as described above.

• 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.

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 3d July 2024.

ANNEX 1 – PERSONAL INFORMATION WE COLLECT

• Category of personal information: Contact details (such as email address and phone number), account details (such as username and password)

  • How we use it: To register you with Mindstone

    • Legal basis for processing: Performance of a contract

  • How we use it: Administration of account (including sending you information regarding changes to our policies, other terms and other administrative information)

    • Legal basis for processing: Performance of a contract

      
      

• Category of personal information: 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)

  • How we use it: To provide you with our services (including displaying your content to you and allowing you to interact with other users)

    • Legal basis for processing: Performance of a contract

      
      

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

  • How we use it: Provision of customer support and to administer the Site (including troubleshooting and resolving technical issues)

    • Legal basis for processing: 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

  • How we use it: For operational reasons, such as improving efficiency, training and quality control

    • Legal basis for processing: It is in our legitimate interests to be as efficient as we can so we deliver the best service for you

      
      

• Legal basis for processing: Contact details (such as email address), marketing and communications data (such as marketing consents and other information you provide us)

  • How we use it: Marketing and advertising (including sending you newsletters and measuring the effectiveness of our marketing)

    • Legal basis for processing: 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

  • How we use it: To respond to queries and complaints and provide you with information and materials that you request from us

    • Legal basis for processing: 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

      
      

• Category of personal information: 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.)

  • How we use it: To administer the Site, including resolving technical issues, troubleshooting, data analysis, testing and research and statistical purposes

    • Legal basis for processing: It is in our legitimate interests to monitor Mindstone to ensure that it functions properly and is secure

  • How we use it: To ascertain your preferences and improve the Site to ensure that content is presented in the most effective manner for you

    • Legal basis for processing: Consent

  • How we use it: Analytics

    • Legal basis for processing: Consent