Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information about how and why we, as controller, collect, store, use, share and protect your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

This privacy policy does not apply to content that we process on behalf of our customers within our products and/or services. Our use of that data is governed by our customer agreements covering access to and use of those offerings.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR).

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Minimum Ltd and, where applicable, our group companies
Privacy Team	privacy@minimum.com
Personal data	Any information relating to an identified or identifiable individual
Special category personal data	Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation
Data subject	The individual who the personal data relates to

Personal data we collect about you

The personal data we collect about you depends on the particular products and/or services we provide to you. We will collect and use the following personal data about you:

Identity Data includes your first name, last name, any previous names, username or similar identifier, including general account information;
Contact Data includes your billing address, delivery address, email address and telephone numbers;
Financial Data includes bank account and payment card details, including details about payments to and from you and other details of products and services you have purchased from us
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website, products and services;
Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses;
Usage Data includes information about how you interact with and use our website, products and services; and
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also use cookies and similar technologies that enable our servers to recognize your web browser, tell us how and when you visit and use our website, analyze trends, learn about our user base, operate and administer our website and improve your experience. For detailed information about the cookies we use, please view our Cookie Declaration.

We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

We typically do not collect special categories of personal data about individuals to deliver for our product and services. In some circumstances, it is necessary for us to process special categories of personal data of our employees. Other than where such personal data is made public by the individual themselves, such processing would only be undertaken as necessary for us to exercise our rights and obligations as an employer (including for occupational health purposes), protect the vital interests of individuals, establish or defend legal claims or with the explicit consent of the individual(s) concerned.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing products and/or services to you.

How your personal data is collected

We use different methods to collect your information, including through:

- Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise, or by creating an account on our product.

- Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

- Third parties, business partners or publicly available sources, for example, our marketing partners who may provide us with information about potential customers of our business services.

How and why we use your personal data

We need to collect your personal data in order to:

manage and deliver our platform and services to you
communicate with you, such as in relation to administrative or account-related information, and respond to your queries
process transactions, such as at the time of purchase or renewal of service
gather feedback to improve our services
seek qualified candidates for employment opportunities with us
enforce legal rights or defend or undertake legal proceedings
ensure our business policies are complied with
improve efficiency, training and quality control
ensure the confidentiality of commercially sensitive information
help us manage our business through statistical analysis, eg in relation to our customer base, our product range and for efficiency improvements
protect the security of systems and data used to provide the services
update and enhance customer records
market our services to:
- existing and former customers;
- third parties who have previously expressed an interest in our services;
- third parties with whom we have had no previous dealings.
comply with external audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts
comply with applicable laws, enforce our terms and conditions, and to protect our operations, rights, safety or property

Our legal basis for processing your data

Our legal basis for collecting and using personal data will depend on the personal data concerned and the specific context in which we collect it. We will normally process your data for the purposes described in this policy, based on one or more of the following legal grounds:

We process your data in order to provide a service you’ve asked for under a contract;.
We may process your data for our legitimate interests and those of third parties, where these are not overridden by your privacy and data protection interests or fundamental rights and freedoms;.
Where relevant, we may process your data when necessary to protect the vital interests of you or another person;.
We process your data when we have a legal obligation to do so; and/or.
In certain cases, we may ask for your consent to process your data for specific purposes and you have the right to withdraw your consent at any time.

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You do, however, have the right to opt out of receiving marketing communications at any time by:

contacting us at the details in “How to Contact Us” or;
using the ‘unsubscribe’ link in emails or;

We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside the Minimum group for marketing purposes.

Who we share your personal data with

We routinely share personal data with:

Minimum group companies;
third parties we use to help deliver our products and services to you, eg payment and transaction service providers, hosting service providers, support and monitoring services, and other technology providers;
other third parties we use to help us run our business, eg marketing agencies or website hosts;
our bank[s];

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

our external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Where your personal data is held

Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.

How long your personal data will be kept

We will only keep personal data for as long as reasonably necessary to fulfil the relevant purposes set out in this Policy Privacy and in order to comply with our legal and regulatory obligations.

How long we retain personal data will depend on a number of factors, such as:

- Our purpose for processing the data (such as whether we need to retain the data to provide our services);

- The amount, nature, and sensitivity of the information;

- The potential risk of harm from unauthorized use or disclosure; and

- Any legal requirements that we are subject to.

If you would like further information regarding the periods for which personal information will be kept, please contact us as set forth in the “How to contact us?” section.

Transferring your personal data out of the UK and EEA

To provide our product and services, we may transfer personal data to other countries, including countries outside of the EEA and the UK which may have different data protection standards to those which apply to your country of residence. Where information is transferred outside the EEA and the UK to a service provider in a country that is not subject to an adequacy decision by the EU Commission, or considered adequate as determined by applicable data protection laws, we will take steps to ensure your personal data is adequately protected by safeguards such as the Standard Contractual Clauses (“SCCs”) approved by the EU Commission, or the UK International Transfer Addendum to the SCCs.

If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal data
Rectification	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object	The right to object: —at any time to your personal data being processed for direct marketing (including profiling). We may need to keep some minimal information to comply with your request to cease marketing to you; —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you Please note that Automated Decision-Making currently does not take place on our websites or in our services.
The right to withdraw consent	If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. This may mean we are not able to provide certain products or services to you and we will advise you if this is the case. Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO).

If you would like to exercise any of those rights, you can email or write to us - see below: ‘How to contact us’. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.please:

Keeping your personal data secure

We implement industry-leading security protocols to safeguard your personal data against accidental loss, unauthorised access, or unlawful use. Access to your information is strictly limited to authorised personnel with legitimate business requirements, all of whom operate under stringent confidentiality obligations. Our commitment to data protection is demonstrated through continuous system testing and our ISO 27001 certification, confirming our adherence to international information security standards. For detailed information about our security practices and compliance certifications, please visit trust.minimum.com.

We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You may also have the right to lodge a complaint with the Information Commissioner (the UK data protection regulator) and/or the relevant supervisory authority in your jurisdiction. Please contact us if you would like further information.

For a list of EEA data protection supervisory authorities and their contact details see here.

Changes to this privacy policy

We may change this privacy notice from time to time—when we do, we will publish the new version on our website, indicating the date of the most recent update at the top of the page.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

How to contact us

You can contact us by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

By Post:

Minimum Ltd
Shiva Building, The Tanneries
55 Bermondsey Street, London, SE1 3XH
United Kingdom

By Email:

privacy@minimum.com