Privacy Policy

1. GENERAL

Meniga Limited and Meniga Group companies (“Meniga” or “we”), respect your privacy and are committed to always protecting your personal data. Meniga works after the principle "My data working for the benefit of me".

This privacy policy, (the “Privacy Policy”), explains which data we collect about you in connection with your use of meniga.com website and its features (the “Website”) and how it is processed and shared and which measures we have taken to keep your data secure. It also describes what rights you have regarding your personal data.

If you want to learn how we use your personal data when you use our services such as Meniga Rewards (i.e. providing offers, rewards and cashbacks which may be linked to your debit or credit card(s), and providing you with interesting offers customized after your interests and purchasing habits) or via Meniga.is (categorizing and analyzing your bank transactions (bank account and credit card transactions) and enabling you to gain an overview of your income and expenses, help analyze your finances and use your resources more efficiently) please check our policies for these services (the ”Services”):

When you use the Website or otherwise interact with us, you acknowledge that you understand that we collect, retain and use your personal data in accordance with this Privacy Policy.

This Privacy Policy applies to the personal data we collect about you in connection with your use of our Website. The Privacy Policy does not apply to your personal data collected via the Services.

This Privacy Policy also does not apply to your personal data collected independently by any of our partners and Meniga disclaims any responsibility for the data processing conducted by such partners.

2. WHO WE ARE

We are Meniga Limited, a private limited company incorporated and registered in England and Wales with company number 08822710 whose registered office is at 10 John Street, London, WC1N 2EB, United Kingdom. You can reach us by e-mail at info@meniga.com or dpo@meniga.com, and we are the data controller for the processing of your personal data.

We trust that this Privacy Policy answers your questions about our collection, use, protection and disclosure of your personal data. If you have additional questions, please contact us on the address or e-mail address provided above.

3. AMENDMENTS

We may amend this Privacy Policy from time to time. If we do so, the amended Privacy Policy will enter into force when we publish it on the Website. The latest date of amendment is stated at the bottom of the Privacy Policy.

If any amendment makes the Privacy Policy less protective of your personal data, such amendment will not apply to data we collected about you before the amendment was made. The amendment will, however, apply to such data if you provide your consent to the new version of the Privacy Policy or otherwise acknowledge its receipt.

4. COLLECTION

4.1 What information we collect

We collect the personal data which has been provided by you or automatically collected through the Website. The personal data or information which does not amount to personal data we collect and further process include the following:

4.1 Information you decide to provide us via the Website

We collect data from you when you enter data through various contact and request forms on our Website, such as requests for demos, marketing materials, analyses or other informational content (the “Resources”) as well as other communication.

The information we collect through these forms may include, your name, work email address, position, company name, industry and work phone number.

4.2 Information collected automatically via the Website

We use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you across the Website and when using different devices.

We use information stored by cookies such as device information and internet protocol address (IP-address) to identify you and log your use.

We may also collect other technical information related to your use of the Website via cookies, such as browser information, any website from which you have been referred; pages you visit in the Website . We may also use analytics services (e.g. Google Analytics) to help us track the efficacy of our Website including Website access location information.

If you set your mobile device or your web browser not to accept cookies the Website may not fully function as intended. For detailed information on cookies and similar technologies we use on the Website please see [LINK TO THE COOKIE POLICY].

5. PROCESSING PURPOSES

Your personal data will not be used in any manner that is incompatible with the purpose for which it was collected. Please note that certain data can be used even without your consent as will be explained below . We process your personal data for the purposes set out in Clauses 5.1-5.5 below.

5.1 Improve the Website

We will process your personal data to produce statistics on how you use our Website. We can do this e.g. by analyzing your use of the Website. When we use your information to improve our Website, we use it in an aggregated form (i.e. study the overall user patterns by reviewing de-identified data) to the extent possible. We use your information to be able to make the Website more user friendly, e.g. by fixing bugs, amending the interface in order for you to easily reach the information that you seek or highlighting popular content or functions. To the extent you information are considered personal data, their processing is based on our legitimate interest to continuously improve the Website.

5.2 Prevent abuse or misuse

Your personal data can also be used to prevent abuse of our Website and its features or to prevent or investigate crimes. Abuse refers to, among other things, fraud, attempt of unauthorized access to the Website, protect against other security threats, for risk management purposes and other measures which are in violation of our terms of service or law. In addition, your personal data can also be used to establish, exercise or defend legal claims. All this processing is based on our legitimate interest to avoid abuse of the Website and protect our rights and interests connected therewith.

5.3 Direct marketing

We use your personal data to communicate with you, to send newsletters, marketing materials, market analyses and relevant information about our products and Services. These communications can be sent to you by e-mail or on occasion delivered to you in a telephone conversation. This processing is based on your prior consent or based on our legitimate interest to communicate with you regarding your prior request to receive any Resources from us.

You may at any time unsubscribe from such direct marketing messages by using the link in any of our emails or by sending a request at marketing@meniga.com.

We will treat your decision to unsubscribe as withdrawal of consent and/or objection to processing based on our legitimate interest (as appropriate). However please be informed that this will not affect the lawfulness of the processing based on consent or our legitimate interest prior to such withdrawal and/or objection.

6. HOW WE SHARE YOUR PERSONAL DATA

We do not sell or assign any of your personal data to any third parties. However, at times the personal data that we collect may be shared with other companies in the Meniga group to for the processing on our behalf or for the centralization of data. If Meniga shares your personal data in such ways, we will ascertain that your information is still processed only in accordance with this Privacy Policy.

 Meniga does not share your personal information with any third party, except as described below.

6.1 Service providers

Meniga may use third parties to manage one of more aspects of our business operations, including the processing or handling of personal information. We may share personal information with such third parties to perform services on our behalf such as processing payments, sending marketing communications, conducting research surveys, verifying and validating information that you have provided to us.

6.2 Sale or transfer of business or assets

Any information we have about you may be transferred or disclosed to a purchaser or prospective purchaser in the event of a sale, assignment, or other transfer of all or a portion of our business or assets. Should such a transfer occur, we will use reasonable efforts to ensure that the transferee uses your information in a manner that is consistent with this Privacy Policy.

6.4 Legal purposes

Meniga may also disclose your information if we are required to do so by law or to comply with legal requests (e.g. disclosure queries, court decisions, legal actions or the like) or when it is necessary to detect, prevent and address fraud and other criminal activity, to protect ourselves, you and other users, including as part of an inquiry if we in good faith believe that such action is required by applicable law. The above may include answering legal requests from non-EU/EEA jurisdictions, where we in good faith believe that the response is required by the law of the relevant jurisdiction, affects users in this jurisdiction and is in accordance with internationally recognized standards.

When we use service providers within the scope of our business in accordance with Clause 6.1 above, we will enter into a data processing agreement with the service provider and take other appropriate measures to ensure that your personal data is processed in accordance with this Privacy Policy.

Processing in accordance with Clause 6.2 above is based on our legitimate interest in being able to govern our assets in the most beneficial way for our clients, end-users of our products and services and for the Meniga group or based on our requirements under law.

7. WE PROTECT YOUR DATA

The files containing your personal information will be stored on our servers and will only be accessible to our employees and those of our agents and service providers who require it in the course of their duties. We maintain appropriate safeguards and current security standards to protect your personal information against unauthorized access, disclosure, or misuse. For example, electronic records are stored in secure, limited-access servers and electronic data is stored behind secured encryption access. We use technological tools like firewalls and multi-factor authentication, and we ensure our employees are trained on the importance of maintaining the security and confidentiality of the personal information we process.

All communications between your device and Meniga (the Website) are encrypted via SSL (Secure Socket Layer).

8. STORAGE PERIOD

We generally retain your personal data as long as it is necessary for the purposes it was collected for or as otherwise required or authorized by applicable law, such as GDPR.

Upon your un-subscription from our direct marketing messages in accordance with Clause 5.3 above, Meniga will, to the extent Meniga does not need to retain data for further periods (e.g. as set out in 8.1 below), erase your personal data from its systems and anonymize all identifiable information related to you. Thus, anonymized data, in de-identified and aggregate forms, may remain on our system indefinitely. We reserve the right to use this aggregate data to improve our service and for other lawful purposes, as discussed above.

8.1 Un-subscription

After your un-subscription from our direct marketing messages in accordance with Clause 5.3 above, Meniga will only retain your personal data to the extent necessary for fulfilment of our legal requirements (including fraud and security threats prevention) or as otherwise required by standard retention practices or as necessary to establish, exercise or defend legal claims.

9. YOUR RIGHTS

You have a right to access your own personal data, to see which personal data we hold about you and to receive a copy of the data upon your request. This right is not absolute, there might be instances where applicable laws or regulations would require us to withhold some of the information relating to you. In such cases we will inform you, to the extent possible, of why some information had to be withheld.

You have a right to have your data rectified, e.g. if some of the data relating to you is wrong, and we encourage you to help us keep your personal information up to date and accurate.

You have a right to request erasure of your data. The right to deletion of data is not absolute.  It might for example apply to information that are wrong, outdated or no longer needed for the purpose it was collected for.

You may also have a right to have the processing of your data restricted, object to processing (where it is based on our legitimate interest) and to have your data transferred to another data controller (data portability). Those rights are limited and will be evaluated on a case-by-case basis.

If you wish to exercise any of those rights, please contact us and our Data Protection Officer at dpo@meniga.com.

If you think we process your data in a way that is not compatible with relevant Data Protection Legislation you are of course free to contact the relevant Data Protection Authority (e.g. Information Commissioner's Office in the UK; ico.org.uk), but we strongly urge you to voice your concerns with the contact named above first, to see if we can rectify the situation.

10. TRANSFER OF PERSONAL DATA

Meniga stores and processes your personal data within the EU/EEA and the United Kingdom. When we or companies within the Meniga Group or our partners conduct business outside the EU/EEA, we will ensure that appropriate protective measures are taken prior to the data transfer to such business.

This Privacy Policy was published on the website in October 2019.