Minter One Limited (‘we’, ‘our’ or ‘us’) may process certain personal data about you, depending on the scope of your specific relationship with us. This processing of personal data is regulated under the General Data Protection Regulation (2016/679) (‘GDPR’) and the e-Privacy Directive (2002/58/EC). We are responsible as ‘controller’ of your personal data for these legal purposes.
This Privacy Notice applies to the following three circumstances:
1. personal data processed when you visit and use our website (“website”); and
2. personal data processed to service our potential and existing customers (“customers”).
Website
When you visit our website, and navigate your way around, we acquire minimum personal data at this stage. The personal data we collect includes the following:
Providing your data is optional, but it may be necessary for certain services we provide, and other processing activities e.g. to access content, or to qualify your suitability as a new customer. In such cases, if you do not provide your personal data, we may not be able to provide you with the requested services.
Customers
As a business, any data solely connected to the legal enterprise is not personal data, however we collect the following personal data on directors and ultimate beneficial owners that you provide to us at onboarding:
We collect this personal data from the directors / partners / trustees, ultimate beneficial owners, key controllers and authorised traders when registering with us. We collect the following personal data that you provide to us throughout the business relationship:
We collect this personal data from you when you:
Website
We do not collect or process personal data from other sources and any personal data we collect, in the context of the website, is provided by you whether directly or indirectly.
Customers
We may receive personal data about your directors and ultimate beneficial owners from other sources, where applicable. This information includes:
We will add this information to the personal data we hold about you for the following purposes:
Please note that we will ask for your explicit consent before any credit search is performed.
We may receive personal data about you from other sources, where applicable. This information includes primarily legal and compliance checks. We will add this information to the personal data we hold about you for the following purposes:
This website uses various services and applications (collectively, “tools”) that are provided either by us or by third parties. These include, in particular, tools that use technologies to store or access information in the terminal device:
Cookies:
Information stored on the terminal device, consisting in particular of a name, a value, the storing domain and an expiration date. So-called session cookies (e.g. PHPSESSID) are deleted after the session, while so-called persistent cookies are deleted after the specified expiration date. Cookies can also be removed manually.
Most browsers are set by default to accept Cookies, the execution of scripts and the display of graphics. However, you can usually adjust your browser settings to reject all or certain Cookies or to block scripts and graphics. If you block Cookies from being stored, graphics from being displayed, and scripts from running entirely, our services are not likely to function properly or at all.
In the following, we list the tools we use by category, informing you in particular about the providers of the tools, the storage period of the Cookies or information in Local Storage and Session Storage, and the transfer of data to third parties. We also explain in which cases we obtain your voluntary consent to use the tools and how you can withdraw it.
Website
We use your personal data mainly to interact with you; to provide you with support services; to make it easy to navigate our website; to improve our website and our products; and to offer you content and services that might interest you.
We use your personal data as follows, where the processing is necessary to establish or administer our agreement with you:
We may also use your personal data where processing is necessary for us to comply with our legal obligations, including responding to legal process or lawful requests. Lastly, we may use your personal data, where required by applicable law.
Customers
We collect personal data about your directors and ultimate beneficial owners for the following purposes:
We may monitor and record communications such as emails and telephone calls for the following purposes:
We may share your personal data with:
This data is never sold or passed on to other companies in order to market services not offered by us.
We collect and use personal data to provide you with a service or product that you have requested, or where necessary, to comply with a legal obligation. We may also collect and use personal data pursuant to our legitimate interest as long as these interests are not overridden by your data protections rights. Additionally, we may collect and use certain personal data where you have given consent. Where we ask for consent, you are free to withhold or revoke your consent by opting out.
We rely on the legal basis of ‘legitimate interest’ and ‘consent’ in order to market to you, with considerations to the e-Privacy Directive and its requirements under consent.
We will keep your personal data in line with our Record Keeping Policy. This allows us to perform the activities listed in this Privacy Notice. We will maintain your personal data throughout the lifecycle of the contract. We may need to keep your data for a longer period where we need to retain personal data to comply with legal or regulatory requirements, such as to help us respond to complaints or preventing fraud and financial crime. If we are not required to retain the personal data, we will destroy, delete or anonymise it at the point it is no longer required.
We store your personal data in a secure environment. We have appropriate security measures in place to prevent personal data from being lost, accessed or used in an unauthorised way, including encryption and other forms of security. We limit access to your personal data to those who have a genuine business need to know it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Whilst we will use all reasonable efforts to secure your personal data, in using the website you acknowledge the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of personal data that is transferred from you.
Your personal data may be transferred to and stored in locations outside the EEA. When we do this, we will ensure the recipient entity has an appropriate level of protection and that the transfer is lawful through controls, such as Standard Contractual Clauses. We may need to transfer your data in this way to carry out our contractual obligations to you, to fulfil a legal obligation and/or for our legitimate interests. In such instances, we will only share the personal data with those who have the right to see the personal data.
We would like to send agents information about products, services and our business, which may be of interest to agents. Such information could be sent by post, email, or telephone.
We will ask whether you would like us to send you marketing messages on the first occasion that you provide any relevant contact information (i.e. on signing up with us). If you do opt in to receive such marketing from us, you can opt out at any time (see ‘13. What rights do you have?’ below for further information). If you have any queries about how to opt out, or if you are receiving messages you do not want to, you can contact us using the details provided below.
We may do a credit check on you so that we can make credit decisions about you and prevent financial crime. Any such search will be recorded on the files of the credit reference agency. We will only check the credit of specific persons depending on the requested service, we will get explicit consent from you if we require a credit search.
If you provide false or inaccurate information to us and we suspect fraud, we will record this.
We would like to make sure you are fully aware of all your data protection rights:
The right to access – You have the right to request us for copies of your personal data and how we process the data.
The right to rectification – You have the right to request that we correct any personal data you believe is inaccurate. You also have the right to request we complete personal data you believe is incomplete.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions. If you enforce this right at the same time as you object to the processing we will have to maintain basic identification data to ensure we do not contact you again.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to our processing of your personal data, this means if you do not want to be contacted for the purposes set out in this notice then we will stop processing your data.
The right to data portability – You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you.
From time to time we may have other methods to unsubscribe (opt-out) from any direct marketing including, for example, unsubscribe buttons or weblinks. If such are offered, please note that there may be some period after selecting to unsubscribe in which marketing may still be received while your request is being processed.
We may update or amend this Privacy Notice from time to time. You should check this Privacy Notice frequently to ensure you are aware of the most recent version that will apply each time you access this website. We will also attempt to notify users of any changes by:
If you have any questions about this Privacy Notice or the personal data we hold about you, please contact us by:
Email – legal@mxon.co
Address – Minter One Ltd, 171 Main Street, PO Box 92, Road Town, Tortola VG1110, British Virgin Islands
If you have any complaints about this Privacy Notice or the personal data we hold about you, please contact us by reaching out to the above contact information.
