Privacy Policy

Privacy Policy

Updated on 30th November 2021

Preamble

In the following privacy policy, you will find everything you need to know about how your data is processed by our mobile application: Mingo App

Consent to installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purpose. We are also obliged to outline your rights in relation to your personal data. This information is provided in [LINK TO POLICY] and it is important that you read that information.

Prior to the installation of this App, please indicate your consent to our processing of your personal data, this includes your name, contact details, financial and device information as described in the policy.

YES – I consent to the installation of the App to access the cryptocurrency wallet and related features.

NO –I do not consent to the installation of the App.

How to withdraw consent

Once you have provided consent by selecting “YES”, you may change your mind and withdraw consent at any time by contacting us at dpo@mingocoin.com. Please be minded that this will not affect the lawfulness of any processing carried out prior to you withdrawing your consent.

Consent to processing Location Data

We may request access or permission to track location-based information from your mobile device, either continuously or while you are using the application. If you wish to change our access or permission, this can be done on your device’s privacy settings.

YES – I consent to the processing of my Location Data (including details of my current location as disclosed by GPS technology) in order to be provided location-based services and unique in-game features.

NO – I do not consent to the processing of my Location Data and location-enabled services are disabled in my settings.

Location Data

Mingo Technologies Limited is committed to protecting your personal data and respecting the privacy of all users.

Introduction

This policy (together with Apple’s end-user licence agreement as set out at [WEB ADDRESS OF EULA] (

  • Mingo v.1 mobile application software (App) hosted on the Apple AppStore, once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
  • Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children, and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing.
  • Where we need to perform a contract, we are about to enter or have entered with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose/activity

Type of data

Lawful basis for processing

To install the App and register you as a new App user

Identity

Contact

Financial

Device

–          Your consent

To process in-App purchases anddeliver Services includingmanaging payments and collecting money owed to us

Identity

Contact

Financial

Transaction

Device

Marketing and Communications

Location

–          Your consent

–          Performance of a contract with you

–          Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you including notifying you of changes to the App or any Services

Identity

Contact

Financial

Profile

Marketing and Communications

–          Your consent

–          Performance of a contract with you

–          Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

–          Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

Toenable you to participate in a prize draw, competition or complete a survey

Identity

Contact

Device

Profile

Marketing and Communications

–          Your consent

–          Performance of a contract with you

–          Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

To administer and protect our business and this App including troubleshooting, data analysis and system testing

Identity

Contact

Device

–          Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content and advertisements to you

To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the advertising we serve you

To monitor trends so we can improve the App

Identity

Contact

Device

Content

Profile

Usage

Marketing/Communications

Location

–          Consent

–          Necessary for our legitimate interests (to develop our products/Services and grow our business)

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

  • Internal Third Parties
  • External Third Parties
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
  •  

Important information and who we are

The controller as defined by Article 4 (7) of the General Data Protection Regulation (hereinafter: GDPR) and other national protection laws is Mingo Technologies Limited. Mingo Technologies Limited is the controller and is responsible for your personal data (collectively referred to as “the Company”, “we”, “us” or “our” in this policy).

Contact details

Our full details are:

Mingo Ventures LLC
First Floor, SVG Teachers Credit Union Uptown Building, Corner of James and Middle StreetKingston P.O. St. Vincent and the Grenadines

Keith Chichon Compliance Officer,  Mingo Ventures LLC

Compliance@mingoapps.com

 

 

 

Changes to the privacy policy and your duty to inform us to changes

We keep our privacy policy under regular review.

This version was last updated on [xx]. These policies may change and if it does, the new policy may be displayed on-screen, and you may be required to read and accept the changes to continue your use of the APP or the Services.

How is your personal data collected?

We will collect and process the following data about you:

  • Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, downloador register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App’s social media functions,enter a competition, promotion or survey, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
  • Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.
  • Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
  • Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Device Data from the following parties:

analytics providers such as Google based outside Gibraltar;

advertising networks; and

search information providers.

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based outside Gibraltar;
  • Identity and Contact Data from data brokers or aggregators; and
  • Identity and Contact Data from publicly available sources.

Cookies

We use cookies [and/or other tracking technologies] to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy [LINK].

International transfers

Under the Data Protection Act 2018, you have a right to access your Personal Data held by the Company, and it is your responsibility to inform the Company of any changes to your Personal Data to ensure such data remains accurate. You also have a right to object to your Personal Data being processed for the purposes of direct marketing. You agree to provide a written request to the Company should you wish to enforce these rights.

 

You agree that the Company may, for the purposes set out above, permit the transfer of your Personal Data to any jurisdiction, whether or not inside the European Economic Area, and that by accepting the Terms you will be authorizing and expressly consent to the processing of your Personal Data by the Company, its agents and/or its service providers, provided that where your Personal Data is processed by entities other than the Company, its agents or its service providers, the Company shall seek your prior written consent in respect of such processing.

Whenever we transfer your personal data out of Gibraltar, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Gibraltar.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing serviceswill be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 3 years then we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

Request access to your personal data

Request correction of your personal data

Request erasure of your personal data

Object to processing of your personal data

Request restriction of processing your personal data

Request transfer or your personal data

Right to withdraw consent

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at dpo@mingocoin.com.

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

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