1 INTRODUCTION
1.1 Important information and who we are
Welcome to Midas AI Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).
At Midas AI Ltd (“we”, “us”, or “our”)we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data ProtectionRegulation (“GDPR”), the Data Protection Act 2018 and all othermandatory laws and regulations of the United Kingdom.
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacyrights, how the law protects you, and inform our employees and staff membersof all their obligations and protocols when processing data.
The individuals from which we may gather and use data can include:
Customers
and any other people that the organisation has a relationship with or may need to contact.
This Privacy Policy applies to all ouremployees and staff members and all Personal Data processed at any time by us.
1.2 Your Data Controller
Midas AI Ltd is your Data Controller andresponsible for your Personal Data. We are not obliged by the GDPR to appointa data protection officer and have not voluntarilyappointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to info@getmidas.ai or by post to 71-75 Shelton Street, Covent Garden,London, WC2H 9JQ, United Kingdom.
You have the right to make a complaintat any time to the Information Commissioner’sOffice (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to dealwith your concerns before you approach theICO so please contact us in the first instance.
1.3 Processing data on behalfof a Controller and processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). The responsibilities below may be assigned to an individual or may be taken to apply to the organisation as a whole.The Data Controller and our Processors have the followingresponsibilities:
Ensurethat all processing of Personal Data is governedby one of the legal baseslaid out in the GDPR (see 2.2 below for more information);
Ensurethat Processors authorised to process PersonalData have committed themselves to confidentiality or are underan appropriate statutory obligation of confidentiality;
Implement appropriate technical and organisational measuresto ensure a level of security appropriate to the risk associated with the processing of Personal Data;
Obtainthe prior specificor general authorisation of the Controller before engaginganother Processor;
Assistthe Controller in the fulfilment of the Controller's obligation to respondto requests for exercising the data subject's rights;
Make available to the Controller allinformation necessary to demonstrate compliance with the obligations laid down in the GDPR and allowfor and contribute to audits, includinginspections, conducted by the Controller or another auditor mandated by theController;
Maintain a record of all categories of processing activities carried out on behalf of aController;
Cooperate, on request, with the supervisory authority in the performance of itstasks;
Ensurethat any personacting under the authority of the Processorwho has access to Personal Data does not process PersonalData except on instructions from theController; and
Notifythe Controller withoutundue delay after becoming aware of a Personal Data Breach.
2 LEGAL BASIS FOR DATA COLLECTION
2.1 Types of data / Privacy policy scope
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed(anonymous data).
We may collect, use, store and transferdifferent kinds of Personal Data about you which we have grouped togetherbelow. Not all of the following types of data will necessarily be collectedfrom you but this is the full scope of data that we collect and when we collectit from you:
Profile/Identity Data: This is data relatingto your firstname, last name,gender, date of birth.
Contact Data: This is data relating toyour phone number, addresses, email addresses, phone numbers.
Marketing and Communications Data: This is your preferences in receivingmarketing information and other information from us.
We do not collect any Special Categories of Personal Data about you (this includesdetails about your race or ethnicity, religiousor philosophical beliefs,sex life, sexual orientation,political opinions, trade union membership, information about your health, andgenetic and biometric data). Nor do we collect any information about criminalconvictions and offences.
2.2 The Legal Basis for Collecting That Data
Thereare a number of justifiable reasons under the GDPR that allow collection and processing of PersonalData. The main avenues we rely on are:
“Consent”: Certainsituations allow us to collectyour Personal Data, such as whenyou tick a box that confirms you are happy to receiveemail newsletters from us, or ‘opt in’ to a service.
“Contractual Obligations”: We may requirecertain information from you in orderto fulfil our contractual obligations and provide you with the promisedservice.
“Legal Compliance”: We’rerequired by law to collect and process certain types of data, such asfraudulent activity or other illegal actions.
“Legitimate Interest”: We mightneed to collectcertain information from you to beable to meet our legitimate interests - this covers aspectsthat can be reasonablyexpected as part of running our business, that will not have a material impacton your rights, freedomor interests. Examplescould be your address, so that we knowwhere to deliver something to, or your name, so that we have a record of who tocontact moving forwards.
3 HOW WE USE YOUR PERSONAL DATA
3.1 Our data uses
We will only use your Personal Data when the law allows us to.
Set out belowis a table containing the different typesof Personal Data we collectand the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the tablebelow.
Examples provided in the table below are indicative in nature and the purposesfor which we use your data may be broader than described but we will never processyour data without a legalbasis for doing so and it is for a related purpose. For further inquiriesplease contact us.
Activity
Type of data
Legal Justification
Lawful basis for processing data
Customer Sign- up
Profile/Identity Data
Contact Data
Consent
Contractual Obligations
We collect this data to create and manage your user profile and to communicate with you.
Product Purchase
Billing Data Financial Data
Transactional Data
Contractual Obligations
Legal Compliance
We need to process this data for billing and to comply with legal requirements related to transactions.
Marketing Communications
Profile/Identity Data
Marketing and Communications Data
Consent
Legitimate Interest
We collect this data to send you marketing communications and to personalise your experience.
Website Analytics
Technical Data Usage Data
Legitimate Interest
We process this data to improve our website and services based on user behaviour.
Customer Support
Profile/Identity Data
Customer Support Data
Contractual Obligations
Legitimate Interest
We collect this data to provide you with customer support and to improve our services.
Transaction History
Financial Data
Transactional Data
Contractual Obligations
Legal Compliance
We are legally required to maintain records of all transactions and to provide you with transaction history.
Research Participation
Profile/Identity Data
Usage Data Other Data
Consent Research
We collect this data for academic or market research purposes, if you opt-in, and to personalise the research.
3.2 Marketing and content updates
You will receive marketing and newcontent communications from us unless you specifically request that you would not like to receive thesecommunications. From time totime we may make suggestions and recommendations to you about goods or services that may be of interest to you.
3.3 Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need touse it for another reason and that reason is compatible with the originalpurpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the originalpurpose, please contactus.
If we need to use your PersonalData for an unrelated purpose,we will notifyyou and we will explain the legal basis whichallows us to do so.
Pleasenote that we may processyour Personal Data without your knowledge or consent,in compliance with the above rules, where this is required or permitted by law.
4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
4.1 Your legalrights
Undercertain circumstances, you have the following rights under data protection laws inrelation to your personal data:
Right to be informed. You have a rightto be informed about our purposes for processing your personaldata, how long we storeit for, and who it will be sharedwith. We have providedthis information to you in this policy.
Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "datasubject access request"). See section 4.5 below for more detailson how you can make a datasubject access request.
Right to rectification. You have a right to requestcorrection of the personal data thatwe hold about you. This enables you to have any incomplete or inaccurate data wehold about you corrected, thoughwe may need to verifythe accuracy of the new data you provide to us.
Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for uscontinuing to process it, where you have successfully exercised your right to objectto processing (see below), where we may haveprocessed your information unlawfully or where we are required to erase your personal data to complywith local law. Note, however,that we may not alwaysbe able to complywith your requestof erasure for specific legalreasons which will benotified to you, if applicable, at the time of your request.
Right to object.You can object to the processing of personal data we hold about you. Thiseffectively allows you to stop or prevent us from processing your personaldata. Note that this is not an absolute right and it only applies in certaincircumstances, for example:
(i) Where we are processing your personal data for direct marketing purposes.
(ii) Where we are relyingon a legitimate interest (or those of a thirdparty) and
thereis something aboutyour particular situation which makes you want to object to processing on this ground asyou feel it impacts on your fundamental rights and freedoms.
(iii) In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimategrounds to process your information which override your rights and freedoms.
Right to restrict processing. You have the right to request the restriction or suppression of theirpersonal data. Note that this is not an absolute right and it only applies in certain circumstances:
(i) If you want us to establish the data's accuracy.
(ii) Where our use of the data is unlawfulbut you do not want us to erase it.
(iii) Where you need us to hold the data even if we no longer requireit as you need it to establish, exerciseor defend legalclaims.
(iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds touse it.
Right to data portability. You have the right to request the transfer of your personal data to you or to a thirdparty. If you make such a request,we will provide to you, or a third party you havechosen, your personal data in a structured, commonly used, machine-readableformat. Note that this right only applies to automated information which youinitially provided consent for us to use or where we used the information toperform a contract with you.
If you wish to make a request under anyof these rights, please contact us at info@getmidas.ai.
4.2 Your controlover Midas AI Ltd’s use of your Personal Data
You may delete your accountat any time – this will remove your accountpage from our systems and our related software.
We guarantee this will delete all stored data.
You can access information associatedwith your account by logging into your account you created with us.
Your account information will be protectedby a password for your privacy and security.You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately andlimiting access to your computer or device and by signing off after you have finishedaccessing your account.
California Privacy Rights: UnderCalifornia Civil Code sections 1798.83-1798.84, California residents areentitled to ask us for a notice identifying the categories of personal customerinformation which we share with our affiliates and/or third partiesfor marketing purposes, and providing contactinformation for such affiliates and/or third parties. If you are a California resident and would like a copyof this notice, please submit a written request to info@getmidas.ai.
4.3 How Midas AI Ltd protects customers' Personal Data
We are concerned with keeping your datasecure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limitednumber of employees who have special access rights to such systemsand are bound by obligations
of confidentiality. If and when we usesubcontractors to store your data, we will not relinquish controlof your Personal Data or expose it to securityrisks that would not have arisen had the data remained in our possession. However, unfortunately no transmissionof data over the internet is guaranteed to be completely secure. It may bepossible for third parties not under the control of Midas AI Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protectyour Personal Data, we cannot ensure or warrant the security of any PersonalData you transmitto us. Any such transmissionis done at your own risk. If you believe that your interaction with us is nolonger secure, please contact us.
4.4 Opting out of marketingpromotions
You can ask us to stopsending you marketing messages at any time by You can ask us to stop sendingyou marketing messages at any time by clicking the Unsubscribe link in our emails..
Whereyou opt out of receivingthese marketing messages,we will continue to retain otherPersonal Data provided to us as a result of interactions with us not related toyour marketing preferences.
4.5 How to request your data and the processfor obtaining it
You will not have to pay a fee to access your PersonalData (or to exercise any of the otherrights). However, if your requestis clearly unfounded, we could refuseto comply with yourrequest.
We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a securitymeasure to ensurethat Personal Data is not disclosed to anyperson who has no rightto receive it. We may also contactyou to ask you for furtherinformation in relation to your requestto speed up our response.
5 YOUR DATA AND THIRD PARTIES
5.1 Sharing your data with third parties
We may also share PersonalData with interested parties in the event that Midas AI Ltdanticipates a change in controlor the acquisition of all or part of our business or assets or with interested parties in connectionwith the licensing of our technology.
If Midas AI Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your PersonalData to a third party as part of or in connection with that transaction. Upon such transfer,the Privacy Policy of the acquiring entity may govern thefurther use of your Personal Data. In all other situations your data will stillremain protected in accordance with this PrivacyPolicy (as amendedfrom time to time).
We may share your Personal Data at any time if required for legal reasonsor in order to enforce ourterms or this Privacy Policy.
6 HOW LONG WE RETAIN YOUR DATA
We will only retain your Personal Data for as long as reasonably necessaryto fulfil the purposeswe collected it for. We may retainyour Personal Data for a longer periodthan usual in the event of a complaint or if we reasonablybelieve there is a prospect of litigation in respect to our relationship withyou.
7 AGE LIMIT FOR OUR USERS
You must not use Midas AI Ltd unless you are aged 16 or older. If you are under 16 and you access MidasAI Ltd by lying aboutyour age, you must immediately stop using MidasAI Ltd.
This website is not intendedfor children and we do not knowingly collect data relatingto children.
8 INTERNATIONAL TRANSFEROF DATA
Your information may be stored andprocessed in the US or other countries or jurisdictions outside the US where Midas AI Ltd has facilities. By using Midas AI Ltd, you are permitting and consenting to the transferof information, including Personal Data, outsideof the US.
9 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
We keep our Privacy Policy under review and will place any updates here. This versionis dated 7 July2023.
By using MidasAI Ltd, you consent to the collection and use of data by us as set out in this Privacy Policy.Continued access or use of Midas AI Ltd will constitute your express acceptance of any modifications to thisPrivacy Policy.
10 INTERPRETATION
All uses of the word"including" mean "including but not limited to" and theenumerated examples are not intended to in any way limit the term which theyserve to illustrate. Any email addresses set out in this policy may be used solely for the purposefor which they are stated tobe provided, and any unrelated correspondence will be ignored. Unlessotherwise required by law, we reserve the right to notrespond to emails, even if they relate to a legitimate subject matter for which we have providedan email address.You are more likely to get a reply if yourrequest or question is polite,reasonable and thereis no relatively obvious otherway to deal with or answer your concernor question (e.g. FAQs, other areas of our website,etc.).
Our staff are not authorised to contracton behalf of Midas AI Ltd, waive rights or make representations (whethercontractual or otherwise). If anything contained in an email from a Midas AI Ltd addresscontradicts anything in this policy,our terms or any officialpublic announcement on our website, or is inconsistent with or amountsto a waiver of any Midas AI Ltdrights, the email content will be read down to grant precedence to the latter.The only exception to this is genuinecorrespondence expressed to be from the Midas AI Ltd legal department.