Your use of this website implies your acceptance of Mint 66 Limited’s privacy and data protection policy, as set out below, whether you are a visitor to the website (“Visitor”) or a logged-in user (“User”), or a corporate customer.
Cookies
We use harmless cookies (small data files) which your browser stores on your computer or other device. The cookies we place there directly do not contain personal information, other than your email address (to speed up your login, if you are a registered User). For more information about how we use cookies, please visit our Cookies Policy.
Legal Protection
We have built some strong legal protection for employees (“Users” in the text below) into both our Client and User Terms. The employer (“Licensee” in the text below; Mint 66 is the “Licensor”) must, as part of the terms of their licence, agree to the following clauses:
- Unless applicable law has been broken, the Licensee’s sole remedy in respect of the breaking by any User of any of the Licensee’s or the Licensor’s rules concerning the permissible content of Contributions shall be to refer the Contribution to the Licensor for resolution howsoever the Licensor sees fit, or use such other mechanism as the Licensor may provide for the Licensee’s use from time to time. The Licensee undertakes not to take or attempt to take additional action against any User for any such alleged breach, whether the Licensee knows or believes the Licensee knows the identity of that User or not;
- The Licensee undertakes to respect and maintain indefinitely the privacy and confidentiality of any information provided by a User that chooses to identify himself or herself to the Licensee, unless otherwise permitted by User at User’s sole discretion;
- The Licensee undertakes not to use the knowledge of a User’s identity, nor to identify or attempt to identify any User, nor to seek to persuade any User to self-identify, for the purpose of or with the intention of discriminating against, taking any disciplinary action against, terminating employment of, selecting for redundancy, selecting for non-renewal of contract or acting in any other way to disadvantage User because of the content of any of User’s Contributions to the Service;
- The Licensee undertakes not to order, coerce, or otherwise require or cause any employee to act contrary to the terms of the User terms and conditions that Users have with the Licensor;
There are similar versions of these in the User terms and conditions, which may be viewed here. We ask these things of your employer to give them an opportunity to demonstrate to you their commitment to maintaining your anonymity. We know you can trust Mint 66 to look after your opinions; our reputation depends on it.
Data Protection
We are the controller of personal data collected from visitors to the public sections of our website (“Visitors”). We collect minimal personal information about Visitors to the public sections of our website, such as your IP address and information about how you use the website such as information about links that you click, pages you view and how long you stayed on each page. The lawful basis we rely on to do this is that it is in our legitimate interests to do so, because it helps us analyse and improve our website, and it does not undermine your fundamental freedoms for us to use your personal data in this way.
When you become a User of the service, we act as the processor of the personal data collected through your registration and use of the service and your employer acts as the controller of your personal data. This means that we process your personal data on your employer’s behalf and on their instructions, however this does not mean that we share your personal data with them.
We do not require much personal data from our Users: first and last name, an email address, and your choice of password, and we encrypt this information with TLS during transmission. We take reasonable technical and procedural precautions to prevent the loss, misuse or alteration of your personal information. We will use the email address you give us to keep in touch with you, to let you know of changes to our service, to inform you of incoming messages, to send you reminders, and for other similar purposes related to the platform. We will not spam you with details of other people’s products.
The lawful basis on which we rely to process the personal data of our Users is that it is necessary for the performance of our obligations under our contract with your employer. If you do not provide your personal data to us, we will be unable to provide the service to you.
Marketing and Communications
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us or the third party directly if you do not wish to receive any marketing materials from us or them.
Corporate Customers
Without your prior written permission, we will never share, either in public or privately, your data or your employees’ comments and ratings. Nor will we share the results of any of your analyses, except in the following cases:
- When anonymously aggregated with other companies’ data
- If you have agreed to participate in our External Comparison service, in which case we will share your anonymous whole-company results with others doing the same
We may monitor the extent to which different facilities within the platform are used, to help us agree priorities for ongoing development efforts.
International Transfers of Personal Data
We may, from time to time, need to transfer your personal data outside of the UK where we use service providers based elsewhere. Where we do so, we ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. We will only transfer your personal data to a country which has been deemed to provide an adequate level of protection for personal data, or where we have in place specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Retaining Personal Data
We will hold your personal information on our systems only for as long as required to provide you with the services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
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 compliance purposes. In some circumstances you can ask us to delete your data (see ‘Your Rights’ below for further information) although this may not always be possible if we are obliged to retain the data for compliance purposes.
In some circumstances we may 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.
We may 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 Visitors accessing a specific website feature.
Use of Cloud Technology
Mint 66 runs in the cloud, specifically on Microsoft’s world class Azure Platform, chosen for its security, performance and reliability, and we use TLS for secure communications with the cloud. Data may be held at any of Microsoft’s Azure installations worldwide, although we tend to select locations to provide optimum performance for our customers. We use our best endeavours to provide you with an uninterrupted service, and Microsoft do the same for us.
Your Rights
As a data subject, you have a number of rights in relation to your personal data. We set out these rights and how you can exercise them below.
- Right of Access: You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”). This right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully.
- Right to Rectification and Erasure: You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue processing it including storing it (you may have heard of this right described as the “right to be forgotten”).
- Right to Object To or Restrict Processing: Where we process your personal data on the basis of a legitimate interest you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid. You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
- Right to Portability: Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format. 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.
- Right to Stop Receiving Communications: Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications).
- Right to Object to Automated Decision Making and Profiling: You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you. We do not carry out automated decision making or profiling.
- Right to Withdraw Consent: You have the right to withdraw consent at any time where we are relying on consent to process your personal data.
When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Our contact details are set out at the bottom of this policy.
Application
This privacy and data protection policy applies to Mint 66, its website and its services, but does not apply to services offered by other companies or individuals, or to other sites linked to from our website.
Change
We may change this policy from time to time by displaying a new version on our website, but if you are a registered user of Mint 66 we will ensure that you are notified of any changes.
Contact
If you have any questions about this policy, please contact privacy@mint66.com or write to us using our contact details here.
