LAST UPDATED: April 13th, 2023
DATA COLLECTION PRINCIPLES AND PRACTICES
The privacy, safety and trust of our users is top priority for MYNE, and we take seriously the responsibility to safeguard and steward our users’ data. This Policy aims to ensure compliance with the
European General Data Protection Regulation as the current highest standard of data protection and privacy in the world. This Regulation sets out the principles with which any party handling personal data must comply in Europe and provides equal or higher standards of privacy and protection than are required in other parts of the world. As global data protection and privacy standards evolve, MYNE will continue to strive to the highest standards and to implement those standards internationally to the best of our ability. At minimum, we will always meet local standards of data and privacy protection to ensure compliance.
MYNE adheres to the following principles of data protection:
● Data processing must be fair to the data subject;
● Our applications don’t collect more data than is needed to provide specific value to our users;
● We make commercially reasonable effort to ensure that the data collected through our
technologies is accurate;
● We don’t store personal data longer than needed for the specified purpose;
● We process data in a way that ensures security, integrity, and confidentiality; and
● We can demonstrate compliance with these principles.
Our practices ensure, in compliance with GDPR, that all personal data will be:
● Processed lawfully, fairly and in a transparent manner in relation to individuals;
● Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public
interest, scientific or historical research purposes or statistical purposes shall not be incompatible with the initial purposes;
● Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
● Accurate and, where necessary, kept up to date; every commercially reasonable step is taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased, or rectified without delay;
● Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
● Stored for longer periods only insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
subject to implementation of the appropriate technical and organizational measures required by the GDPR to safeguard the rights and freedoms of individuals; and
● Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction
or damage, using appropriate technical or organizational measures.
Please keep in mind that when you provide information to us on a third-party site or platform (for example, via our applications), the information you provide may be separately collected by the
WHO RECEIVES YOUR DATA
Data collected by the Myne system is shared with authorized personnel within the organization and, when necessary, the Poverty Stoplight API for processing purposes. Data may also be shared with third-party service providers, such as Heroku and Amazon Web Services, for storage and hosting.
COUNTRIES WHERE DATA IS TRANSFERRED
Myne stores data in Heroku Postgres, which has data centers in the United States and Europe, and Amazon S3, which has data centers globally. Data may be transferred between these locations for storage, processing, or backup purposes.
TYPES OF INFORMATION WE COLLECT
We collect two basic types of information – personal information and anonymous information – and we may use personal and anonymous information to create a third type of information, aggregate information (also defined in this policy).
“Personal information” means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, postal address, email address, and telephone number. When anonymous information is directly or indirectly associated
with personal information, the resulting information is also treated as personal information.
“Anonymous information” means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual. “Aggregate information” means information about groups or categories of individuals, which does not identify and cannot reasonably be used to identify an individual.
In particular, we collect:
● Registration information you provide when you create an account, such as your first name and surname, postal address, email address, phone number, unique personal identifier, username, and password;
● Demographic information, such as date of birth and country of residence;
● Characteristics of protected classifications, such as racial or ethnic origin, color, sex, gender identity and expression, age, and data concerning health including health insurance provider (if
● Psychographic information and inferences drawn, such as behavioral characteristics, preferences, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes;
● Education information that is not publicly available, such as school name and grades and student identification codes (if elected)
● Information you provide in public forums on our sites and applications, such as your public posts;
● Information sent either one-to-one or within a limited group using our message, chat, post, or
similar functionality, where we are permitted by applicable law to collect this information;
● Information we obtain from a third party, such as a site or platform provider, about use of our
applications on third-party platforms or devices;
● Location information, including precise or approximate location information provided by a mobile or other device interacting with one of our sites or applications, or associated with your
IP address or other online or device identifier, where we are permitted by law to process this information;
● Activity information about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the content you view or post, how often you use
our services, and your preferences; and
● Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, including your browser or device type,
unique device identifier, and IP address.
HOW WE COLLECT YOUR INFORMATION
● We collect information you provide to us when you request or purchase services or information
from us, register with us, participate in public forums or other activities on our sites and
applications, or otherwise interact with us using one or more devices.
● We collect information through a variety of technologies, such as cookies, Flash cookies, pixels,
tags, software development kits, and application program interfaces, including when you visit
our sites and applications using one or more devices. Please see Your Controls and Choices for
further information on how to make choices with respect to such data collection.
● We collect information using analytics tools when you visit our sites and applications.
● We acquire information from other trusted sources to update or supplement the information
you provided, or we collected automatically, such as when we validate postal address
information using third-party services. Applicable law may require that you authorize the third
party to share your information with us before we can acquire it.
USE OF YOUR INFORMATION
Consistent with applicable law and choices and controls that may be available to you, we may use
information collected from you, or from devices associated with you, to:
● Providing functionality
− To facilitate your use of the services and provide you with related customer service;
− To respond to your inquiries and fulfill your requests and transactions, such as when you contact us via one of our online contact forms, or request information about our services; or
− To send administrative information to you, such as changes to our terms, conditions, and policies.
● Providing you with our marketing materials
− To send you marketing related emails, with information about our services, new products, and other news about our company; or
− To facilitate social sharing functionality that you choose to use.
● Analyzing Your Information for business reporting and providing personalized services
− To analyze or predict our users’ preferences to prepare aggregated trend reports on how our
digital content is used, so we can improve our services.
− To better understand your interests and preferences, so that we can personalize our
interactions with you and provide you with information or offers tailored to your interests.
● Aggregating and anonymizing Personal Information
− We may aggregate or anonymize your information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
● Accomplishing our business purposes
− For our business purposes, such as data analysis, security, identity verification, audits, developing new products, improving or modifying our services, identifying usage trends, determining the effectiveness of promotional campaigns, and operating and expanding business activities.
− Detecting, investigating, and preventing activities that may violate our policies, pose safety issues, or be fraudulent or illegal.
SHARING YOUR INFORMATION
We will not share your information with a third party except in limited circumstances, including:
● To our third-party service providers, to facilitate services they provide to us, such as website hosting, data analysis, payment processing, order fulfillment, information technology and related
infrastructure provision, customer service, email delivery, auditing, and other services.
● By using the services, you may elect to disclose your information.
− On message boards, chat, blogs, and other services to which you can post information and content. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Other Uses and Disclosures
We may also use and disclose Personal Information as we believe to be necessary or appropriate:
(a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons or in other cases if we believe in good faith that disclosure is required by law;
(b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, or that of you, or others. We may use, disclose, or transfer your information to a third party in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets or stock (including in connection with any bankruptcy or similar proceedings).
YOUR CONTROL AND CHOICES
We provide you with the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with applicable law, your controls and choices may include:
● The right to access – You have the right to request copies of your personal information.
● The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you
believe is incomplete.
● The right to erasure – You have the right to request that we erase your personal data.
● The right to restrict processing – You have the right to request that we restrict the processing of your personal data.
● The right to object to processing – You have the right to object to our processing of your personal data.
● The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you.
If you desire to exercise these controls and choices, you may write to us at Myne | Myne Contact
(mynetogether.com). You may choose to delete your account and all its information in our Myne Champions app.
Please be aware that if you do not allow us to collect your information, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate.
We recognize the need to provide further privacy protections with respect to information we may collect from children on our sites and applications. Some of the features on our sites and applications are age-gated so that they are not available for use by children, and we do not knowingly collect information from children in connection with those features. When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including:
● Notifying parents about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information;
● In accordance with applicable law, and our practices, obtaining consent from parents for the collection of personal information from their children, or for sending information about our products and services directly to their children;
● Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity; and
● Giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or
DATA SECURITY, INTEGRITY, AND RETENTION
The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your information for
DATA TRANSFER, STORAGE, AND PROCESSING GLOBALLY
These steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring information.
changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our sites and applications, or by other means, consistent with applicable law.
COMMENTS AND QUESTIONS
CALIFORNIA RESIDENTS’ RIGHTS
Notice to California Residents: If you are a California resident, you may have certain additional privacy rights. Visit the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code 1798.100, et seq. for more information, including how Authorized Agents may make certain requests on behalf of California Residents.
UK, EU, AND EMEA RESIDENTS’ RIGHTS
Notice to UK & EU Residents: If you are an EU or UK resident, you may have certain additional privacy rights. We have aligned with GDPR compliance in creating these policies and practices.
For residents of countries in the Middle East, Africa, and European countries that are not part of the EU, you may have certain additional privacy rights.
BRAZILIAN RESIDENTS' RIGHTS
Notice to Brazilian Residents: If you are a Brazilian resident, you may have certain additional privacy rights.