Privacy Policy

PRIVACY POLICY

Effective Date: March 27, 2024

We respect the privacy of our users and website visitors (“users”, “you” or “your”) and are committed to protecting your Personal Information. In order to provide our official websites, www.miinto.com and any other website or application maintained

by us (collectively the “Site”) offered by Miinto Trading EU A/S, a private limited company organized under the laws of the country of Denmark (“Miinto” “we”, “us”, or “our”), collects and processes your Personal Information (as defined below).

This Privacy Policy applies to all aspects of our Services and sets out how we collect, store, process, transfer, share, and use your Personal Information. By using our Services, you acknowledge that you agree to our collection and use of your Personal Information in accordance with this Privacy Policy. If you do not consent to this Privacy Policy, you should immediately stop using all Miinto Services of any kind.

Miinto may use your Personal Information in order to continue to develop and improve upon our Services to benefit our users. Occasionally, Miinto may revise this Privacy Policy without notice to you unless required by applicable law. As such, we encourage you to periodically review this Privacy Policy page to understand the changes. Updates to this Privacy Policy are effective as of the Effective Date at the top of this Privacy Policy, unless otherwise stated or as required by applicable law, by continuing to use our Services, you agree to the revised Privacy Policy to the fullest extent permitted by applicable law.

If you are a resident of California or Nevada, you should read this policy and applicable sections below for residents of California and Nevada.

Please review this Privacy Policy in full to completely understand your rights. Additionally, please also review the Miinto Conditions of Use Agreement, which also apply to the use of our Site. Terms that are defined in the Conditions of Use Agreement have the same meaning as terms that are defined in this Privacy Policy.

I. Personal Information Collection and Processes

a. Information you give us. We may use your Personal Information to provide and improve the Services and your experience on our Site. “Personal Information” refers to all information collected by Miinto relating directly or indirectly to an Miinto user, from which it is practicable for the identity of the user to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable. Such Personal Information may include, without limitation, IP addresses, email addresses, your name, cookies, and other usage data.

b. Collection of Personal Information. We collect Personal Information about you when you voluntarily submit information directly to us by filling forms on our Site and through our Services or by corresponding with us by email or other means. Additionally, we also use a variety of techniques to collect and store such Personal Information, including cookies, pixel tags, and local storage, including, without limitation, browser network storage or application data cache, database, and server logs.

i. Our Website and Its Content. Miinto collects the information sent by your browser when you use our Site and Services from your computer or mobile device (“Log Data”). This Log Data includes, without limitation, your computer's IP address, browser type, browser version, pages visited, access time and date, time spent on specific pages, and various other data. In addition, we may use third-party services such as Google Analytics to collect, monitor, and analyze such information to enhance the functionality of our services. These third-party service providers have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Please be aware that these third parties may have their own privacy policies that explain how they use this information. For more information on the privacy practices of Google Analytics, please visit Google’s Privacy & Terms web page.

ii. Registration and Identity Authentication. The first step to using our Services is by creating an Miinto account. When you create an account, you will need to provide data, including your email address, phone number, password, or other information. If you refuse to provide the foregoing information, we will be unable to provide you with our Services

iii. Log-in and Use of Miinto. When you log into Miinto, we will collect Log Data, as well as your mobile number, email address, password, and any other information you voluntarily provide.

iv. Technical Support. In order to provide technical support to you, and protect the safety of our products, services, and other users, we will use Log Data and any other data you voluntarily provide as necessary. If you do not agree to provide any requested data in order to provide technical support, you will be deemed to have rejected our support.

v. Subscription Service. Upon your express consent or request, we will send you information about products and services you might be interested in, invite you to our promotional activities and market surveys, or send marketing information to you. If you do not want to receive such information, you can opt-out at any time by emailing us at dataprotection@miinto.com.

vi. Service Quality Improvements. We will use Log Data to provide users with a personalized experience, including credit-to-issue services and other special services. In order to do so, we will carry out internal auditing, data analysis, and research; analyze business operation efficiency; and measure other metrics to improve our products and services. We will also provide options that are not based on your Personal Information, or convenient opt out capabilities shall be provided to you as far as practicable.

vii. Feedback. We will also collect user feedback you voluntarily provide. The feedback you choose to provide is important to help us improve its services.

To process your feedback, we may use the Personal Information you provide to contact you and keep records.

viii. Other Information. From time to time, we may collect other information in order to comply with all applicable laws and regulations and enforce our Conditions of Use Agreement.

c. Processing of Personal Information. We process your Personal Information in accordance with the principles of lawfulness, legitimacy, necessity, good faith, transparency, and quality assurance, for the purposes of and in the manner and to the extent described in this Privacy Policy. If the information we collect contains any sensitive Personal Information about you, we will comply with the laws surrounding data in the jurisdiction in which you reside.

II. Methods We Use To Collect Information

a. Cookies. In order to enhance your experience, we use “cookies” to allow us to identify your browser and store user preferences and other information. Cookies are text files stored by a web server on a computer or mobile device, and the content of a cookie can be retrieved and read only by the server that created the cookie. Cookies are unique to the specific browser or mobile application you are using. The text in a cookie often consists of identifiers, site names, and some numbers and characters. You may modify the acceptance of cookies or reject our cookies if your browser or browser's additional services allow it. However, in some cases, rejecting our cookies may affect your Site experience and your ability to use our Services.

b. Web Beacons and Pixel Tags. Miinto and third parties may also use web beacons and pixel tags on websites. A web beacon is an electronic graphic image embedded into a website or email to identify your device cookies when you browse the website or email. Web beacons or similar technologies may not be visible to you and will be used for a number of purposes. Pixel tags allow us to send emails in a way that is readable to you and find out whether an email is opened. Miinto and some third parties use these technologies for various purposes, including analyzing service usage (together with cookies) and providing more satisfactory content or advertisements to you. For example, when you receive an email from us, it may contain a click-through URL that links to an Miinto web page. If you click the link, we will track your visit to help us learn about your preferences for products and services so we can improve upon our Site and Services. You can unsubscribe from our mailing list or discontinue your use of our Site at any time if you do not wish to provide your information in this manner.

c. Other Local Storage. Miinto and some third parties may use other local storage technologies, including, without limitation, local shared objects (also known as “Flash Cookies”) and HTML5 local storage, in certain products and services. Similar to cookies, these technologies store information on your device and can record some information about your activities and preferences. However, these technologies may use different media from cookies. Therefore, you may not be able to control them using standard browser tools and settings.

For details about how to disable or delete information contained in Flash Cookies, click here.

d. Do Not Track. Many web browsers provide a Do Not Track function that can release Do Not Track requests to websites. Currently, major internet standardization organizations have not established policies to specify how websites should handle these requests. If you enable Do Not Track in your browser, Miinto will respect your selection.

III. How We Share Information

a. Internal Sharing. We may share your Personal Information with any member of our organization, which includes any department or subsidiary now known or created in the future. We will not share your Personal Information with any third parties except as described in this Privacy Policy or in connection with our Services. We may share your information with selected third parties including the entities specifically described in this Section III.

b. Entrusted Third Parties. We may entrust third parties to process your Personal Information on our behalf. For example, companies that handle hotlines, send emails, and provide technical support on our behalf. Such companies may only use your Personal Information for the purposes of providing services to you. Upon termination of the partnership, we will request that the entrusted party delete your relevant Personal Information. We will have in place stringent confidentiality agreements and terms governing the handling of Personal Information with the entrusted companies, requiring them to process Personal Information in accordance with this Privacy Policy and relevant confidentiality and security measures. These third parties may include, without limitation, business partners, vendors, subcontractors, and other parties who perform services on our behalf; analytics and search engine providers that assist us in improving our Services; and payment processors for the purpose of fulfilling relevant payment transactions.

c. Provision. Provision refers to a process in which we provide Personal Information to other information processors where both parties have independent procession over the Personal Information. By agreeing to this Privacy Policy, you agree that we may provide your Personal Information under the following circumstances:

i. Provision of Personal Information to an authorized third party;

ii. Provision pursuant to laws and regulations:

1. In certain circumstances, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet law enforcement requirements;

2. We may disclose Personal Information in order to comply with any Miinto legal obligation, or in order to enforce or apply our Conditions of Service and other agreements; or to protect the rights, property, or safety of Miinto, our customers, or others; and

iii. Provision with business partners: we may share your information with our cooperative partners and other third parties with your account information, operational data, and Log Data to provide you with products and/or services you request. However, we will share your Personal Information only for a lawful, proper, necessary, specific, and explicit purpose and only such Personal Information as is necessary to provide our Services.

iv. If the transfer of Personal Information is involved in a merger, acquisition or bankruptcy or insolvency proceeding, we will require new companies or organizations holding your Personal Information to continue to be bound by this Privacy Policy; otherwise, we will require such companies or organizations to seek authorization from you again.

IV. Information Security

Miinto takes commercially reasonable security measures to ensure that Personal Information submitted to use remains secure and protected. However, no method of transmission over the internet, or other methods of electronic storage, is completely secure and your use of our Services and transmission of Personal Information is at your own risk. If you have any questions about our information security, please contact at customerservice@miinto.com.

V. International Transfers

Your Personal Information will be collected, processed, and stored directly on or transferred to our servers in Denmark, and may be transferred to other countries where Miinto, Miinto affiliates, and our third-party business partners maintain facilities or business operations. We will comply with the requirements in relation to the storage of your Personal Information in the applicable jurisdictions. You agree that your Personal Information may be transferred and accessed outside of the jurisdiction in which you reside. Jurisdictions may have different data protection laws or even no relevant laws at all. No matter where your Personal Information is located, Miinto takes commercially reasonable measures to safeguard your privacy rights in accordance with this Privacy Policy. If you do not agree to the collection, processing, storage, and transfer of your Personal Information, please do not provide your information to us, stop using our site, and contact us at dataprotection@miinto.com.

VI. Third-Party Links

Our services may include links to third-party websites that are not operated by us. If you click on a third-party link, you will be directed to the third-party website. This Privacy Policy does not apply to third-party websites. We strongly encourage you to review the privacy policy of the websites you visit. We cannot control the content and privacy policies of any third-party website or service and Miinto will not be responsible for their policies.

VII. Children's Privacy

a. Our Services are intended for a general audience and not for use by anyone younger than the age of 13 in the United States (or under the applicable legal age outside of the United States). We do not knowingly collect or maintain personal data on our website from people under the age of 13, and no part of our website will target individuals under the age of 13. If you are under the age of 13 (or under the applicable legal age outside of the United States, please do not use or access this website in any way.

b. When we learn that we have inadvertently collected personal data from individuals under the age of 13, we will remove or take other appropriate measures in accordance with applicable laws and regulations.

c. Any individuals under the age of 18 cannot use our Services without the consent of a parent or legal guardian. If you are a parent or legal guardian who believes that we have collected or used your child’s Personal Information without your consent, please contact us at customerservice@miinto.com.

VIII. Change of Personal Information Usage Purpose

a. If we decide to use your personal data for any purpose other than this Privacy Policy, we will notify you and obtain your prior consent in accordance with applicable laws and regulations, or provide you with a valid opt-out opportunity for you to choose not to provide your Personal Information to us.

b. We may send you emails about new services and new events. You can refuse to receive promotional emails from us by selecting the “Unsubscribe” feature in each email we send. However, you agree that users of the Services will continue to receive other important emails related to the Service.

IX. Information Retention Time

We will only retain your Personal Information for the period required to achieve the purposes stated in this Privacy Policy, unless there is a mandatory retention period required by law. After the retention period, we will delete or anonymize your Personal Information as required by applicable law. If we cease to operate the website or the relevant services, we will promptly cease the collection of your Personal Information and will post a cease operation notice. Besides, we will delete or anonymize the Personal Information we store.

X. Manage Personal Information

a. Consult, Change, or Delete. Laws in some countries and regions in which we provide Services require us to provide for rights requests in regard to the consulting, changing, or deletion of the processing of related Personal Information by Miinto. In such countries or regions, the subject of the Personal Information or the authorized person ("Requestor") may make a request to us for consultancy of, change of, or deletion of the relevant Personal Information retained by us (hereinafter collectively referred to as the "Request").

i. Requesting Information. A Request for a Personal Information subject must be made in writing by emailing us at dataprotection@miinto.com, unless otherwise required by the applicable law. The requests may be valid even when the requester does not specify the laws on which the Requests are based. If you would like to request access to your Personal Information held by us or if you believe any of your Personal Information that we have is incorrect or incomplete, please submit your request to our email. A copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra requests for the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.

ii. Validity of Request. Most laws require entities requesting Personal Information to comply with specific requirements when they initiate requests. This Privacy Policy requires entities requesting Personal Information to:

1. Submit requests through our email at customerservice@miinto.com;
2. Provide sufficient information for us to verify the relevant identities in accordance with the law of the jurisdiction to which it applies (to ensure those who initiate the requests are the data subjects themselves or those authorized by them); and
3. Ensure that their requests are specific and feasible. There are some circumstances, provided by laws and regulations, in which we may not have to comply with the request in full or at all.

b. Withdraw Consent: You can change the subsequent authorized Personal Information collection scope or withdraw your consent by deleting information, disabling related functions of your device or app, or setting privacy options on your device or app. You may also withdraw all authorization for us to continue collecting your Personal Information by terminating your account.

c. Understand that some basic corresponding Personal Information is required for our Services. When you withdraw your consent or authorization, we may not be able to continue to provide our Services to you. However, your decision to withdraw your consent or authorization will not affect the processing of personal data previously carried out on the basis of your previous authorization.

d. Terminating Your Account. You can terminate your account by contacting us at dataprotection@miinto.com. After you terminate your account, we will stop providing our Services to you. After a reasonable amount of time, we will also delete your personal data unless otherwise required by law. Your account cannot be restored after termination. You will need to register a new account if you want to use our Services again.

XI. California Privacy Notice

a. As effective as of the Effective Date, this California Privacy notice applies only to California residents and sets forth the rights of California users regarding their Personal Information as required by the California Consumer Privacy Act of 2018 (“CCPA”).

b. The CCPA provides California users with the following:

i. The right to know about the Personal Information our business collects about them and how it is used and shared;

ii. The right to delete personal information collected from them;

iii. The right to opt-out of the sale of their Personal Information; and iv. The right to non-discrimination for exercising the rights herein.

c. You may submit a request to (1) know the Personal Information Miinto collects, (2) delete your Personal Information, and (3) opt-out of the sale of your Personal Information by contacting us at dataprotection@miinto.com. You must provide your full name, any username associated with our Site and Services, address, email address, statement detailing which type of request you are making, and electronic or physical signature certifying you are a California resident. We may require you to provide further information.

XII. Notice to Nevada Residents

a. Currently, Miinto sell your “covered information” as defined under Nevada law. This may change in the future. As such, you may submit an opt-out request, which we will adhere to as required by the law of Nevada should we participate in such a sale in the future.

b. You must submit an opt-out request by contacting us at dataprotection@miinto.com. You must provide your full name, any username associated with our Site and Services, address, email address, and electronic or physical signature certifying you are a Nevada resident. We may require you to provide further information related to your residency.

XIII. Contact Us

If you have any questions, concerns, or suggestions regarding our Privacy Policy or if you believe that our Personal Information processing has damaged your legitimate rights and interests, please contact us by emailing customerservice@miinto.com. You should be aware that our response time varies depending on the type of request. We will make a good faith effort to ensure our response complies with all requirements of law in the relevant jurisdictions.