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Privacy Policy

Last updated: January 2024

This Privacy Policy describes Our policies and procedures on the collection, use and

disclosure of Your information when You use the Service and tells You about Your

privacy rights and how the law protects You. We use Your Personal data to provide and

improve the Service. By using the Service, You agree to the collection and use of

information in accordance with this Privacy Policy.
 

Interpretation and Definitions
 

Interpretation

The words of which the initial letter is capitalized have meanings defined under the

following conditions. The following definitions shall have the same meaning regardless

of whether they appear in singular or in plural.
 

Definitions

For the purposes of this Privacy Policy:
 

You means the individual accessing or using the Service, or the company, or other legal

entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR (Genera lData Protection Regulation), You can be referred to as the Data

Subject or as the User as you are the individual using the Service.

Company (referred to as either "the Company", "We", "Us"or "Our" in this Agreement)

refers to

miPWR Ltd, 55 Colmore Row, Birmingham, England, B3 2AA

For the purpose of the GDPR, the Company is the Data Controller.

Application means the software program provided by the Company downloaded by You

on any electronic device, named “CODE 3i”.

Application Store means the digital distribution service operated and developed by Apple

Inc. (Apple App Store) or Google Inc. (Google Play Store) in which the Application has

been downloaded.

Affiliate means an entity that controls, is controlled by or is under common control with a

party, where "control" means ownership of 50% or more of the shares, equity interest or

other securities entitled to vote for election of directors or other managing authority.

Account means a unique account created for You to access our Service or parts of our

Service.

Website refers to mipwr.com, accessible from https://mipwr.com

Service refers to the Website or Application

Country refers to United Kingdom
 

Service Provider means any natural or legal person who processes the data on behalf

of the Company. It refers to third-party companies or individuals employed by the

Company to facilitate the Service, to provide the Service on behalf of the Company, to

perform services related to the Service or to assist the Company in analysing how the

Service is used. For the purpose of the GDPR, Service Providers are considered Data

Processors.
 

Third-party Social Media Service refers to any website or any social network website

through which a User can log in or create an account to use the Service.
 

Personal Data is any information that relates to an identified or identifiable individual.

For the purposes for GDPR, Personal Data means any information relating to You such

as a name, an identification number, location data, online identifier or to one or more

factors specific to the physical, physiological, genetic, mental, economic, cultural or

social identity. For the purposes of the CCPA, Personal Data means any information that

identifies, relates to, describes or is capable of being associated with, or could

reasonably be linked, directly or indirectly, with You.

Cookies are small files that are placed on Your computer, mobile device or any other

device by a website, containing the details of Your browsing history on that website

among its many uses.

Device means any device that can access the Service such as a computer, a mobile

phone or a digital tablet.

Usage Data refers to data collected automatically, either generated by the use of the

Service or from the Service infrastructure itself (for example, the duration of a page visit).

Data Controller, for the purposes of the GDPR (General Data Protection Regulation),

refers to the Company as the legal person which alone or jointly with others determines

the purposes and means of the processing of Personal Data.

Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities,

in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to

develop and implement a mechanism for allowing internet users to control the tracking of

their online activities across websites.

Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the

Company as the legal entity that collects Consumers' personal information and

determines the purposes and means of the processing of Consumers' personal

information, or on behalf of which such information is collected and that alone, or jointly

with others, determines the purposes and means of the processing of consumers'

personal information, that does business in the State of California.

Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a

natural person who is a California resident. A resident, as defined in the law, includes (1)

every individual who is in the USA for other than a temporary or transitory purpose, and

(2) every individual who is domiciled in the USA who is outside the USA for a temporary

or transitory purpose.

Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling,

renting, releasing, disclosing, disseminating, making available, transferring, or otherwise

communicating orally, in writing, or by electronic or other means, a Consumer's Personal

information to another business or a third party for monetary or other valuable

consideration.

Collecting and Using Your Personal Data
 

Types of Data Collected
 

Personal Data

While using Our Service, We may ask You to provide Us with certain personally

identifiable information that can be used to contact or identify You. Personally

identifiable information may include, but is not limited to:

• Email address

• First name and last name

• Phone number

• Address, State, Province, ZIP/Postal code, City

• Usage Data

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include

information such as Your Device's Internet Protocol address (e.g. IP address), browser

type, browser version, the pages of our Service that You visit, the time and date of Your

visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain

information automatically, including, but not limited to, the type of mobile device You

use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile

operating system, the type of mobile Internet browser You use, unique device identifiers

and other diagnostic data. We may also collect information that Your browser sends

whenever You visit our Service or when You access the Service by or through a mobile

device.
 

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service

and store certain information. Tracking technologies used are beacons, tags, and scripts

to collect and track information and to improve and analyse Our Service. You can

instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent.

However, if You do not accept Cookies, You may not be able to use some parts of our

Service. Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain

on your personal computer or mobile device when You go offline, while Session Cookies

are deleted as soon as You close your web browser. Learn more about cookies: All

About Cookies. We use both session and persistent Cookies for the purposes set out

below:

• Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available

through the Website and to enable You to use some of its features. They help to

authenticate users and prevent fraudulent use of user accounts. Without these

Cookies, the services that You have asked for cannot be provided, and We only

use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies Administered by: Us Purpose: These Cookies identify

if users have accepted the use of cookies on the Website.

• Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You

use the Website, such as remembering your login details or language

preference. The purpose of these Cookies is to provide You with a more

personal experience and to avoid You having to re-enter your preferences every

time You use the Website.

• Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the

Website and how users use the Website. The information gathered via these

Cookies may directly or indirectly identify you as an individual visitor. This is

because the information collected is typically linked to a pseudonymous

identifier associated with the device you use to access the Website. We may

also use these Cookies to test new advertisements, pages, features or new

functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding cookies,

please visit our Cookies Policy or the Cookies section of our Privacy Policy.
 

Use of Your Personal Data
 

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our

Service.

• To manage Your Account: to manage Your registration as a user of the Service.

The Personal Data You provide can give You access to different functionalities

of the Service that are available to You as a registered user.

• For the performance of a contract: the development, compliance and undertaking

of the purchase contract for the products, items or services You have purchased

or of any other contract with Us through the Service.

• To contact You: To contact You by email, telephone calls, SMS, or other

equivalent forms of electronic communication, such as a mobile application's

push notifications regarding updates or informative communications related to

the functionalities, products or contracted services, including the security

updates, when necessary or reasonable for their implementation.

• To provide You with news, special offers and general information about other

goods, services and events which we offer that are similar to those that you

have already purchased or enquired about unless You have opted not to receive

such information.

• To manage Your requests: To attend and manage Your requests to Us.

We may share your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service

Providers to monitor and analyse the use of our Service, to contact You.

• For Business transfers: We may share or transfer Your personal information in

connection with, or during negotiations of, any merger, sale of Company assets,

financing, or acquisition of all or a portion of our business to another company.

• With Affiliates: We may share Your information with Our affiliates, in which case

we will require those affiliates to honour this Privacy Policy. Affiliates include Our

parent company and any other subsidiaries, joint venture partners or other

companies that We control or that are under common control with Us.

• With Business partners: We may share Your information with Our business

partners to offer You certain products, services or promotions.

• With other users: when You share personal information or otherwise interact in

the public areas with other users, such information may be viewed by all users

and may be publicly distributed outside. If You interact with other users or

register through a Third-Party Social Media Service, Your contacts on the Third-

Party Social Media Service may see Your name, profile, pictures and description

of Your activity. Similarly, other users will be able to view descriptions of Your

activity, communicate with You and view Your profile.
 

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the

purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the

extent necessary to comply with our legal obligations (for example, if we are required to

retain your data to comply with applicable laws), resolve disputes, and enforce our legal

agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is

generally retained for a shorter period of time, except when this data is used to

strengthen the security or to improve the functionality of Our Service, or We are legally

obligated to retain this data for longer time periods.
 

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating

offices and in any other places where the parties involved in the processing are located.

It means that this information may be transferred to — and maintained on — computers

located outside of Your state, province, country or other governmental jurisdiction where

the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information

represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is

treated securely and in accordance with this Privacy Policy and no transfer of Your

Personal Data will take place to an organization or a country unless there are adequate

controls in place including the security of Your data and other personal information.
 

Disclosure of Your Personal Data
 

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data

may be transferred. We will provide notice before Your Personal Data is transferred and

becomes subject to a different Privacy Policy.
 

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal

Data if required to do so by law or in response to valid requests by public authorities

(e.g. a court or a government agency).
 

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action

is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Service

• Protect the personal safety of Users of the Service or the public

• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of

transmission over the Internet, or method of electronic storage is 100% secure. While

We strive to use commercially acceptable means to protect Your Personal Data, We

cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to Your Personal Data only to perform their tasks on Our

behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service providers to monitor and analyse the use of our Service

• Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and

reports website traffic. Google uses the data collected to track and monitor the

use of our Service. This data is shared with other Google services. Google may

use the collected data to contextualise and personalise the ads of its own

advertising network. You can opt-out of having made your activity on the Service

available to Google Analytics by installing the Google Analytics opt-out browser

add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js

and dc.js) from sharing information with Google Analytics about visits

activity.For more information on the privacy practices of Google, please visit the

Google Privacy & Terms web page: https://policies.google.com/privacy

GDPR Privacy

Service Providers have access to Your Personal Data only to perform their tasks on Our

behalf and are obligated not to disclose or use it for any other purpose.

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or

more specific purposes.

• Performance of a contract: Provision of Personal Data is necessary for the

performance of an agreement with You and/or for any pre-contractual

obligations thereof.

• Legal obligations: Processing Personal Data is necessary for compliance with a

legal obligation to which the Company is subject.

• Vital interests: Processing Personal Data is necessary in order to protect Your

vital interests or of another natural person.

• Public interests: Processing Personal Data is related to a task that is carried out

in the public interest or in the exercise of official authority vested in the

Company.

• Legitimate interests: Processing Personal Data is necessary for the purposes of

the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to

the processing, and in particular whether the provision of Personal Data is a statutory or

contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to

guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the

information We have on You. Whenever made possible, you can access, update

or request deletion of Your Personal Data directly within Your account settings

section. If you are unable to perform these actions yourself, please contact Us to

assist You. This also enables You to receive a copy of the Personal Data We

hold about You.

• Request correction of the Personal Data that We hold about You. You have the

right to to have any incomplete or inaccurate information We hold about You

corrected.

• Object to processing of Your Personal Data. This right exists where We are

relying on a legitimate interest as the legal basis for Our processing and there is

something about Your particular situation, which makes You want to object to

our processing of Your Personal Data on this ground. You also have the right to

object where We are processing Your Personal Data for direct marketing

purposes.

• Request erasure of Your Personal Data. You have the right to ask Us to delete or

remove Personal Data when there is no good reason for Us to continue

processing it.

• Request the transfer of Your Personal Data. We will provide to You, or to a thirdparty

You have chosen, Your Personal Data in a structured, commonly used,

machine-readable format. Please 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 Your consent. You have the right to withdraw Your consent on using

your Personal Data. If You withdraw Your consent, We may not be able to

provide You with access to certain specific functionalities of the Service.

Your Rights under the GDPR

You may exercise Your rights of access, rectification, cancellation and opposition by

contacting Us. Please note that we may ask You to verify Your identity before

responding to such requests. If You make a request, We will try our best to respond to

You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and

use of Your Personal Data. For more information, if You are in the European Economic

Area (EEA), please contact Your local data protection authority in the EEA.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

 

CCPA Privacy
 

Your Rights under the CCPA

Under this Privacy Policy, and by law if You are a resident of California, You have the

following rights:

• The right to notice. You must be properly notified which categories of Personal

Data are being collected and the purposes for which the Personal Data is being

used.

• The right to access / the right to request. The CCPA permits You to request and

obtain from the Company information regarding the disclosure of Your Personal

Data that has been collected in the past 12 months by the Company or its

subsidiaries to a third-party for the third party's direct marketing purposes.

• The right to say no to the sale of Personal Data. You also have the right to ask

the Company not to sell Your Personal Data to third parties. You can submit

such a request by visiting our "Do Not Sell My Personal Information" section or

web page.

• The right to know about Your Personal Data. You have the right to request and

obtain from the Company information regarding the disclosure of the following:

- The categories of Personal Data collected

- The sources from which the Personal Data was collected

- The business or commercial purpose for collecting or selling the Personal Data

- Categories of third parties with whom We share Personal Data

- The specific pieces of - Personal Data we collected about You

• The right to delete Personal Data. You also have the right to request the deletion

of Your Personal Data that have been collected in the past 12 months.

• The right not to be discriminated against. You have the right not to be

discriminated against for exercising any of Your Consumer's rights, including by:

- Denying goods or services to You

- Charging different prices or rates for goods or services, including the use of

discounts or other benefits or imposing penalties

- Providing a different level or quality of goods or services to You

- Suggesting that You will receive a different price or rate for goods or services

or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if you are a California

resident, You can email or call us or visit our "Do Not Sell My Personal Information"

section or web page.

The Company will disclose and deliver the required information free of charge within 45

days of receiving Your verifiable request. The time period to provide the required

information may be extended once by an additional 45 days when reasonable necessary

and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers we partner with (for

example, our advertising partners) may use technology on the Service that "sells"

personal information as defined by the CCPA law.

If you wish to opt out of the use of your personal information for interest-based

advertising purposes and these potential sales as defined under CCPA law, you may do

so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out

on every browser that you use.

Website

You can opt out of receiving ads that are personalized as served by our Service

Providers by following our instructions presented on the Service:

• From Our "Cookie Consent" notice banner

• Or from Our "CCPA Opt-out" notice banner

• Or from Our "Do Not Sell My Personal Information" notice banner

• Or from Our "Do Not Sell My Personal Information" link

The opt out will place a cookie on Your computer that is unique to the browser You use

to opt out. If you change browsers or delete the cookies saved by your browser, you will

need to opt out again.
 

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the

apps you use in order to serve you ads that are targeted to your interests:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android

devices

• "Limit Ad Tracking" on iOS devices*

You can also stop the collection of location information from Your mobile device by

changing the preferences on your mobile device.

"Do Not Track" Policy as Required by California Online Privacy Protection Act

(CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are

visiting such websites, You can set Your preferences in Your web browser to inform

websites that You do not want to be tracked. You can enable or disable DNT by visiting

the preferences or settings page of Your web browser.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California

residents with an established business relationship with us can request information once

a year about sharing their Personal Data with third parties for the third parties' direct

marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if

you are a California resident, You can contact Us using the contact information provided

below.

California Privacy Rights for Minor Users (California Business and Professions Code

Section 22581)

California Business and Professions Code section 22581 allow California residents

under the age of 18 who are registered users of online sites, services or applications to

request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, You can contact

Us using the contact information provided below, and include the email address

associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of

content or information posted online and that the law may not permit or require removal

in certain circumstances.

Links to other websites

Our Service may contain links to other websites that are not operated by Us. If You click

on a third party link, You will be directed to that third party's site. We strongly advise You

to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or

practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes

by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the

change becoming effective and update the "Last updated" date at the top of this Privacy

Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to

this Privacy Policy are effective when they are posted on this page.

Contact us

If you have any questions about this Privacy Policy, You can contact us:

By email: support_team@mipwr.com

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