Privacy Policy


Last Updated Date: September 15, 2020


This privacy and cookie policy (“Policy”) describes how the Minerva Project Inc.  (“Company,” “we,” and “our”) collects, uses and shares personal data when using this website www.minervaproject.com (the “Site”). Please read the following information carefully to understand our views and practices regarding your personal data and how we will treat it. 

Particularly Important Information

Who we are: For the purpose of applicable data protection legislation, the data controller of your personal data is the Minerva Project Inc.  of 1145 Market Street. Floor 9, San Francisco, CA 94103. 

Must Read Sections: We draw your attention in particular to the sections entitled “International Data Transfer” and “Your Rights.” 

Changes to this Policy: We will post any modifications or changes to the Policy on our Site. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will post a notice on our Site prior to such changes(s) taking effect.


1. PURPOSES OF PROCESSING

What is personal data?
We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the General Data Protection Regulation 2018 and any successor legislation, this includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.

Why do we need your personal data?
We will only process your personal data in accordance with applicable data protection and privacy laws. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Site.

2. COLLECTING YOUR PERSONAL DATA

We collect information about you in the following ways:

Information You Give Us. This includes:

  • the personal data you provide if you choose to contact us, including your‎ name, professional title, email address, and organization
  • the personal data you provide when you correspond with us by phone, email or otherwise


Information We Get from Others. We may also get information about you from other sources, for example, if you have agreed to share information with one of our partners or we may add this to information we get from Site.

Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Site, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site. We collect this information about you using cookies. Please refer to the sections on cookies below.

Automated Decision Making and Profiling. We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.


3. COOKIES

What are cookies?

We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on our Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below: 

Basic Cookies: Basic cookies help us make our Site usable by enabling basic functions like page navigation, access to secure areas of the website, and helping the content of the pages you request load quickly. The Site cannot function properly without these cookies.


Analytics Cookies: Statistic cookies help us understand how visitors interact with our Site by collecting and reporting information anonymously.

These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered does not identify any individual visitor. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.

Marketing cookies: Marketing cookies are used to track visitors across websites, including our Site. These help us measure and understand the effectiveness of our advertising campaigns across other third-party services.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility).  Many browsers are set to accept cookies until you change your settings.  

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.


4. DO NOT TRACK SIGNALS

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.


5. USING YOUR PERSONAL DATA

We may use your personal data as follows:

  • to operate, maintain, and improve our Site, products, and services;
  • to respond to your comments and questions and to provide customer service;
  • to send information including technical notices, updates, security alerts, and support and administrative messages;
  • with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates.  You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you; 
  • as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
  • as described in the “Sharing of your Personal Data” section below.



6. SHARING YOUR PERSONAL DATA
We may share your personal data as follows:

  • Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
  • Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as educational services, data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
  • Partners. We may share some or all of your personal data with our affiliates, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them.
  • Organization Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
  • Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.


7. ANONYMOUS DATA

When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.  

We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies.  We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you.  We use this anonymous data to analyses usage patterns in order to make improvements to our Site.


8. THIRD PARTY SITES 

Our Site may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies.  Please read their privacy policies before you submit any data to them. 


9. INTERNATIONAL DATA TRANSFER 

Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Site, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.


10. SECURITY
Minerva Project takes reasonable measures to protect your personal information in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration, and destruction. We take the following steps to help keep your data secure:

  • We encrypt data transmissions using SSL technology.
  • We have reasonable measures in place to protect the physical security of records we store on our premises.
  • We restrict access to personal information to Minerva Project employees, contractors, and agents who need to know that information in order to process it for us or as part of their job requirements, and who are subject to confidentiality or employment agreements.

Minerva Project will never ask you for financial information or for your account password in an email or phone call. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 16 below.


11. RETENTION
We will only retain your personal data as long reasonably required for you to use the Site unless a longer retention period is required or permitted by law (for example for regulatory purposes). 


12. OUR POLICY ON CHILDREN
Our Site is not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in Section 16 below. We will delete such information from our files as soon as reasonably practicable.


13. SENSITIVE PERSONAL DATA
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership, or institutional data and material that is confidential) on or through our Site or otherwise to us.


14. YOUR RIGHTS

  • Opt-out.  You may contact us anytime to opt-out of direct marketing communications.
  • Access. You may access the information we hold about you at any time by contacting us directly. 
  • Amend. You can also contact us to update or correct any inaccuracies in your personal data.
  • Move. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish. 
  • Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data. 

If you wish to exercise any of these rights, please contact us using the details in Section 16 below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce.  For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.


15. COMPLAINTS
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: privacy@minervaproject.com. We will reply to your complaint as soon as we can. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.


16. CONTACT INFORMATION
We welcome your comments or questions about this Policy. You may contact us in writing at privacy@minervaproject.com or 1145 Market Street, Floor 9, San Francisco, CA 94103