Privacy Policy
Thank you for your interest in us and your visit to our website (this “Site”), which is owned and operated by Mirana Ventures Limited, a BVI company (together with its affiliated entities, “Mirana”, “we” or “us”).
Mirana is committed to respecting and protecting your privacy. Please read this Site Privacy Policy (“Privacy Policy”) carefully in order to understand what information Mirana collects about visitors to this Site, and how Mirana uses and discloses that information. For specific information relating to the Careers page of the Site, please see the “Careers” section below. By using or accessing this Site in any way, you acknowledge that you have read, understood and hereby accept the practices and policies outlined in this Privacy Policy, and you hereby consent to our collection, use and sharing of your information in the manner described herein (unless you are located in the EEA/UK, where we rely on a different basis for processing your personal information as outlined at “Privacy Policy Addendum for the EEA and the UK” below). If you do not agree with the content of this Privacy Policy, please discontinue the use of this Site.
This Privacy Policy covers our treatment of your personal information that we collect or receive when you access or use our Site, but not to the practices of companies we do not own or control, or people that we do not manage, nor to the privacy practices of any entity with whom Mirana (or any of our affiliates) has an investment relationship, even if you are able to access such entity’s website or service through a link on this Site.
This Privacy Policy also does not apply to personal information obtained outside of the Site such as through offline correspondence, in the course of our recruitment and selection processes, or through other personal contacts with representatives of Mirana or its affiliates.
Types of Information Collected
Mirana collects both personal information (which includes personal identifiers) and non-personal information from your interactions with us via this Site. Personal information is information, that can directly or indirectly cause you to be identified based on the information.
In the context of the Site, the personal information we may collect includes:
- Name;
- Identification number;
- Contact information (email address and/or phone number);
- Postal address;
- Company;
- Job role;
- Website usage information (cookies information, IP address, browser type and version); and
- Such other information you may submit to us via the Site (or the contact details provided on the Site).
Information Collected Automatically
Mirana may collect personal information during your visit to this Site through our automatic data collection tools, which may include cookies and other commonly used information-gathering tools. These tools collect certain information that your browser sends to our website such as your browser type and language, access times, and the address of the website from which you arrived at this Site. They may also collect information about your IP address, geolocation information, and information about your device.
Cookies
Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help you to navigate on websites efficiently as well as to provide information to the owner of the website. Cookies do not contain any software programs. There are two general categories of cookies, session cookies and persistent cookies. Session cookies are only used during a session online and will be deleted once you leave a website. Persistent cookies have a longer life and will be retained by the website and used each time you visit a website. Both session and persistent cookies can be deleted by you at anytime through your browser settings and in any event, will not be kept longer than necessary.
When you visit this Site, Mirana may place a “cookie” in order to improve your experience by recognizing you when you visit this Site. Cookies may also be used to compile information about website usage. If you subsequently provide us with personal information such as your email address, we may associate any cookies on your browser with that information. Web browsers often allow you to erase existing cookies from your hard drive, block the use of cookies and/or be notified when cookies are encountered. If you elect to block cookies, please note that you may not be able to take full advantage of the features and functions of the Site.
If you click on a link to a third-party website or service, a third party may place cookies on your device. This Privacy Policy does not cover the use of cookies by any third parties, and we are in no way responsible for their privacy policies and practices.
How Mirana Uses and Shares Personal Information
Mirana may use personal information you provide in order to:
- Respond to your inquiries;
- Evaluate your business plan or profile and determine whether we are interested in engaging with you; or
- Improve our website and services;
- Reorganise or make changes to our business; and
- Recruitment and selection.
To the extent permitted under applicable law, Mirana may share information (including in aggregate form (i.e., that cannot reasonably identify a particular individual)) with third parties for business purposes, such as consultants, auditors, contractors, agents, legal advisors and/or courts of law, regulators, service providers, potential investors/purchasers, and advisors to Mirana. Mirana may disclose your personal information to a third party if required to do so by applicable laws and to comply with legal, regulatory or other professional obligation such as:
- Comply with applicable laws, court order or with other legal process;
- Protect and/or defend Mirana’s rights and property or prevent fraud;
- Protect Mirana against abuse, misuse or unauthorized use of Mirana’s products or services; or
- Protect the rights, safety and/or property of its personnel, affiliates, users of this Site or others, including but not limited to advisers, law enforcement, judicial and regulatory authorities.
Mirana may also transfer personal information you provide to a third party that acquires all or part of Mirana’s assets or shares, or that succeeds Mirana in carrying on all or a part of Mirana’s business, whether by merger, acquisition, reorganization or otherwise.
Non-Confidentiality of Certain Information Submitted to Us
Mirana is not responsible for protecting against misuse or disclosure of any confidential or proprietary information that may be disclosed through this Site, in the absence of Mirana’s express written agreement to do so.
Except as expressly set forth in this Privacy Policy with respect to personal information and non-personal information you submit in connection with this Site may be used or disclosed by Mirana for any purpose and in any manner, as Mirana determines in its sole discretion. Please consider this carefully before sending Mirana any information or other materials that you deem confidential or proprietary.
Information Security
Mirana has put in place appropriate information security measures to prevent personal information from being accidentally lost, accessed, altered, disclosed, used or destroyed in an unauthorized way (or other similar risks). We take various measures to ensure information security, personal information stored electronically are password-protected. Encryption technology is used on our secured web areas. Our computer systems are placed in restricted areas.
Hyperlinks
The Site may, from time to time, contain links to external sites operated by third parties for your convenience. Mirana has no control of and are not responsible for these third-party sites or the content thereof. Once you leave the Site, Mirana is not responsible for the protection and privacy of any information which you provide to these third-party sites. You should exercise caution and look at the privacy statement for the website you visit.
Access and Deletion
Visitors in the EU/UK and Singapore may have additional privacy rights, for more information please refer to the specific country addendum below.
Subject to exceptions set out in applicable laws, you have the right to obtain specific pieces of personal information we have collected from you upon request and ascertain whether the information we hold about you is accurate and up-to-date. We will provide access within 30 days of your request. If we refuse to provide the information, we will provide reasons for the refusal. We will require identity verification and specification of what information is required before providing you with access. If any of your personal information is inaccurate, you may request to update your information.
Where we are satisfied that the request to update the information is accurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. You may also request to delete your personal information, with the exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes. For data access, correction, or deletion requests, or to request withdrawal of your previously provided consent, please send an email with your request to [email protected].
International Transfers of Personal Information
If you are located in the EEA or UK, please refer to the Privacy Policy Addendum for the EEA and the UK.
In accordance with and as permitted by applicable law and regulations, we reserve the right to transfer your personal information, process and store it outside your country of residence to wherever we or our third party service providers operate. Visitors in the EU/UK should refer to the Privacy Policy Addendum for the EEA and the UK below.
Changes to this Privacy Policy
We encourage you to check this Site frequently to see the current Privacy Policy in effect and any changes that may have been made to them. This Privacy Policy may be updated or otherwise modified by us at any time. To the extent permitted under applicable law, your continued use of this Site after any such updates or modifications constitutes your acceptance of such updated or modified Privacy Policy.
Contact Information
Any questions, concerns or complaints regarding this Privacy Policy should be sent to [email protected].
PRIVACY POLICY ADDENDUM FOR THE EEA AND THE UK
This Privacy Policy Addendum supplements the information contained in the main Privacy Policy and applies to visitors of the Site generally and Careers page of the Site for all individuals (“you”) that reside in the United Kingdom (“UK”) and/or Economic European Area (“EEA”) This section is intended for compliance with the General Data Protection Regulation (“GDPR”) and the UK version of the GDPR.
Legal basis for processing personal information under the GDPR and UK GDPR
When we use your personal information, we ensure we have a lawful basis to do so. In the table below, we have set out the relevant lawful basis that applies to each processing activity for which we use your personal information.
Processign activity
Types of personal information processed
Lawful basis for processing
Correspondence and responding to your inquiries
- Name;
- Identification Number;
- Contact information (email address and/or phone number);
- Postal address;
- Company;
- Job role;
Legitimate interest
(to provide our services)
Evaluate your plan or profile and determine whether we are interested in engaging with you
- Name;
- Identification Number;
- Contact information (email address and/or phone number);
- Postal address;
- Company;
- Job role;
Legitimate interest
(to provide our services)
Improve our Site and services
- Website usage information (cookies information, IP address, browser type and version)
Legitimate interest
( to improve our Site and services)
Exercise our legal rights or defended claims
- Name;
- Identification Number;
- Contact information (email address and/or phone number);
- Postal address;
- Company;
- Job role;
Legal obligation
(where the processing activity is required by law or regulation)
In all other cases, legitimate interests (to comply with our obligations)
To reorganise or make changes to our business
- Name;
- Identification Number;
- Contact information (email address and/or phone number);
- Postal address;
- Company;
- Job role.
In some instances, we may collect personal information which may be considered 'sensitive' such as:
- Immigration status;
- Health information;
- Information relating to criminal convictions.
Legitimate interest
(restructuring our business)
For any sensitive personal information processed (such as health information or information concerning racial or ethnic origins). we may also rely on substancial public interest (regulatory requirements, insurance and safeguarding) or for legal claims.
Recruitment (specifically relating to our Careers page)
- Assessing your suitability for the advertised role
- Communicating with you in connection with your expression of interest
Any information provided by you in response to an advert displayed on our Careers page.
Legitimate interests
(to enable us to effectively recruit staff)
For any sensitive personal information processed (such as health information or information concerning racial ethnic origins), we may also rely on employment legal obligations.
International Transfers of Personal Information
As an international company, we may store or transfer your personal information to other Mirana entities around the world. Where this is the case, we will ensure that the importing jurisdiction offers an adequate level of data protection, or we will provide the personal information under a comprehensive, flexible, and global compliance framework which implements appropriate measures and safeguards to ensure that your personal information is protected in accordance with applicable data protection laws.
Similarly, where we transfer personal information to a third party located in a different jurisdiction, we will ensure that appropriate measures are in place to ensure an adequate level of protection for your personal information, such as by including appropriate clauses in our agreements with third parties.
Our retention periods for personal information are based on business needs and legal requirements. We will retain your personal information while we are using it, for purposes described above. We may continue to retain it after we have ceased such uses for certain legitimate business purposes.
The length of time for which we will retain your personal information will depend on the purposes for which we need to retain it. After we no longer need to retain your personal information, we will delete it or securely destroy it in accordance with our records retention policy.
Retention
UK and EEA Privacy Rights
Under certain circumstances (and subject to exemptions) you have rights under data protection laws in relation to your personal information. If you wish to exercise any of the rights set out below, please refer to the “Contact Us” section below.
Access.
You have the right to access and receive a copy of your personal information, and other supplementary information.
Rectification.
You have the right to have inaccurate personal information rectified, or completed if it is incomplete.
Objection.
You have the right, when we process personal information on the grounds of legitimate interests, to object to the processing of your personal information for compelling and legitimate reasons relating to your particular situation, except in cases where legal provisions expressly provide for that processing. In addition, you have the right to object at any time where your personal information is processed for direct marketing purposes.
Portability.
You have the right to receive your personal information that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit them to other data controllers without hindrance. This right only exists if the processing is based on your consent or a contract and the processing is carried out by automated means.
Restriction.
You may request to restrict processing of your personal information (i) while we verify your request – if you have contested the accuracy of the personal information about you which we hold; (ii) if the processing is unlawful and you oppose the erasure of it and request restriction instead; (iii) if we no longer need it, but you tell us you need it to establish, exercise or defend a legal claim; or (iv) while we verify your request if you have objected to processing based on public or legitimate interest.
Erasure.
You may request to erase your personal information if it is no longer necessary for the purposes for which we have collected it, you have withdrawn your consent and no other legal grounds for the processing exists, you objected and no overriding legitimate grounds for the processing exist, the processing is unlawful, or erasure is required to comply with a legal obligation.
Right to refuse or withdraw consent.
Please note that in case we ask for your consent to certain processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your personal information that occurred prior to the withdrawal of your consent will not be affected.
Right to lodge a complaint.
You also have the right to lodge a complaint with a supervisory authority, in the jurisdiction of your residence, or the location where the issue that is the subject of the complaint occurred.
- Details of the UK data protection authority can be found at www.ico.org.uk.
- Details of the applicable data protection supervisory authority for EEA jurisdictions can be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Contact Us
If you are a resident or citizen of the UK or EEA and have an unresolved privacy or data use concern, please contact [email protected] in the first instance.