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Mirello App Ltd ("us", "we", or "our") operates the Mirello mobile application (the "Service"). This Privacy Policy outlines our policies regarding the collection, use, and disclosure of personal data when you use our Service, as well as your rights and choices regarding your data.
This Privacy Policy applies to your use of the Mirello mobile application and any other platforms or versions of the Service that may be made available, including but not limited to web applications.
We are committed to safeguarding your privacy and ensuring that your personal data is protected. We process your data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR) where relevant.
By using the Service, you agree to the collection and use of information in accordance with this policy. You also have certain rights regarding your data, which are described in detail in this policy.
Unless otherwise defined in this Privacy Policy, the terms used have the same meanings as in our Terms and Conditions.
Service
The Service refers to the Mirello mobile application and the company website (mirello.app) operated by Mirello Ltd. This includes all platforms on which the Service is available, including mobile applications, web applications, and any other digital services provided by Mirello.
Personal Data
Personal Data refers to any information about a living individual that can be used to identify them, either directly or indirectly. This includes, but is not limited to, data such as your name, email address, billing information, journal entries, and other content you provide through the Service.
Usage Data
Usage Data is information collected automatically through your interaction with the Service or through the Service’s infrastructure. This may include information such as your device's Internet Protocol (IP) address, browser type, browser version, device type, pages visited, the time and date of your visit, the time spent on those pages, app usage patterns, and diagnostic data for error reporting.
Cookies
Cookies are small files placed on your device (computer or mobile device) that allow us to recognise your browser or device, and store certain information. We use cookies for various purposes, including session management, analytics, and tracking user preferences. You can manage your cookie preferences in your browser settings.
Data Controller
The Data Controller is the person or organisation who determines the purposes and means of processing personal data. For the purposes of this Privacy Policy, Mirello Ltd is the Data Controller of your Personal Data.
Data Processors (or Service Providers)
A Data Processor is a natural or legal person who processes personal data on behalf of the Data Controller. We use trusted third-party Service Providers to assist in the operation of our Service, including hosting, data analysis, payment processing, and customer support.
Data Subject (or User)
A Data Subject is any individual who uses our Service and whose Personal Data is collected and processed by Mirello.
We collect several types of information for various purposes to provide, maintain, and improve our Service, as well as to enhance your overall experience. The data we collect helps us understand how users interact with the Service and allows us to provide better customer support and ensure the security of our platform.
Personal Data
While using our Service, we may ask you to provide personally identifiable information that can be used to contact or identify you ("Personal Data"). This information is necessary to create and manage your account, provide access to subscription services, and enable certain features within the Service. Personally identifiable information may include, but is not limited to:
In addition to this, you may also provide personal content such as journal entries, goals, and responses to questionnaires. This data remains private and is used solely for providing the Service to you.
Usage Data
When you access the Service via a mobile device or web browser, we may collect certain information automatically. This data may include details about your device, such as the type of mobile device you use, your device’s unique identifier, IP address, mobile operating system, and other diagnostic data ("Usage Data"). This helps us understand user interaction with the app and troubleshoot issues.
Tracking & Cookies Data
We use cookies and similar tracking technologies to track activity on our Service (including the Mirello website) and retain certain information. Cookies help us remember user preferences, manage sessions, and ensure the security of our platform.
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, some portions of our Service may be unavailable.
Examples of cookies we use:
For more details, please refer to our Cookie Policy.
Mirello Ltd uses the data we collect for various purposes, including:
Service Provision and Maintenance
Analytics & Improvement
Security and Technical Maintenance
Legal Compliance and Obligations
Mirello Ltd will retain your Personal Data only for as long as is necessary to fulfill the purposes outlined in this Privacy Policy, such as providing and maintaining the Service, complying with legal obligations, resolving disputes, and enforcing our agreements and policies.
We will retain and use your Personal Data as long as your account remains active, and for a reasonable period thereafter, unless a longer retention period is required by law. If you choose to delete your account, we will delete or anonymize your Personal Data, except where retention is required by legal obligations or for legitimate business purposes.
Usage Data is generally retained for a shorter period of time, typically 12 months, unless it is used for improving security, functionality, or required for legal purposes. We may retain Usage Data for longer if it is necessary to strengthen the security of our Service or improve performance, but only as long as necessary for these purposes.
Upon request, users may contact us to have their Personal Data deleted or anonymized, in accordance with applicable data protection laws.
All data that is no longer required will be securely deleted or anonymized in a way that ensures it cannot be restored.
Your information, including Personal Data, may be transferred to and maintained on computers located outside your state, province, country, or other governmental jurisdiction, where the data protection laws may differ from those in your jurisdiction.
If you are located outside the United Kingdom and choose to provide information to us, please note that your data, including Personal Data, will be transferred to the United Kingdom for processing. In such cases, we ensure that adequate safeguards are in place to protect your data, in accordance with applicable data protection laws, such as the General Data Protection Regulation (GDPR).
Legal Safeguards for International Transfers
Mirello Ltd will take all reasonable steps to ensure that your data is transferred securely and that no transfer of your Personal Data will take place to an organization or country unless appropriate safeguards are in place. These safeguards may include the use of Standard Contractual Clauses (SCCs), binding corporate rules, or transfers to countries that have been deemed to provide an adequate level of data protection.
Third-Party Data Transfers
In cases where we rely on third-party service providers to process your Personal Data, these providers are required to follow strict contractual obligations, including security measures and data protection requirements, ensuring that your data is treated with the same level of care and security.
User Rights
By consenting to this Privacy Policy and submitting your information, you agree to the transfer of your data as described. If you have concerns about your data being transferred, or if you wish to withdraw consent, you may contact us at any time.
Mirello Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:
In such cases, data may be shared with law enforcement authorities, regulatory bodies, or other third parties, as required by law. Where permissible and appropriate, we will notify you if your data is being disclosed in response to legal obligations.
Mirello Ltd is committed to ensuring that any data disclosed is limited to what is necessary to fulfill the legal requirement, and that user privacy is respected in all instances.
The security of your data is of utmost importance to us. While no method of transmission over the internet or electronic storage is 100% secure, we strive to use robust, industry-standard practices to protect your Personal Data.
We employ a variety of security measures, including encryption, access control, and regular security audits, to safeguard your data from unauthorized access, alteration, or disclosure. We continuously monitor our systems for vulnerabilities and take steps to mitigate risks.
However, it is important to remember that absolute security cannot be guaranteed. We encourage you to help protect your data by using strong, unique passwords and keeping your login credentials confidential.
In the event of a security breach that affects your Personal Data, we will take appropriate steps to inform you and any relevant regulatory authorities, in accordance with applicable data protection laws.
Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Mirello Ltd aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at mirello.app@gmail.com.
In certain circumstances, you have the following data protection rights:
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyse the use of our Service.
Google Analytics
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors we work with are:
Our Service may contain links to third-party websites or services that are not operated by Mirello Ltd. 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 and terms of service of every site you visit to understand how they handle your data.
Please note that Mirello Ltd has no control over and assumes no responsibility for the content, privacy practices, or policies of any third-party websites or services. The inclusion of these links on our platform does not imply endorsement or affiliation with those sites.
Once you leave our Service, any information you provide or actions you take will be subject to the privacy and security practices of the third-party site, and we recommend that you exercise caution before sharing your Personal Data.
Our Service is not intended for individuals under the age of 18 ("Children"), and we do not knowingly collect personally identifiable information from anyone under this age.
In compliance with applicable data protection laws, if you are a parent or guardian and you become aware that your Child has provided us with Personal Data without your consent, please contact us immediately. If we discover that we have collected Personal Data from children without parental verification or consent, we will take prompt steps to delete that information from our servers and prevent further access to the Service for the child.
If local laws in your jurisdiction set a different age for the collection of Personal Data (e.g., under 13 in some regions), we comply with those laws and take appropriate measures to ensure that no data is collected from users below the minimum age threshold.
We may update our Privacy Policy from time to time to reflect changes in our practices, services, or legal obligations. Any changes will be posted on this page, and we will update the "effective date" at the top of the Privacy Policy.
For material changes—those that significantly affect your rights or the way we use your personal data—we will notify you at least 60 days before the changes take effect. You will be notified via email and/or a prominent notice within the Service. We encourage you to review the updated Privacy Policy during this period.
By continuing to use the Service after any changes become effective, you agree to the revised Privacy Policy. If you do not agree with the changes, you may stop using the Service and delete your account before the changes take effect.
We encourage you to periodically review this Privacy Policy for any updates or changes.
If you have any questions about this Privacy Policy, please contact us by email: mirello.app@gmail.com
