Last updated: August, 2022

Your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means) will be processed as necessary for the performance of our contractual obligations towards you and providing you with our services and products (including, without limitation, any content therein) and the operation of our websites and mobile apps and delivery of emails to you (collectively the “Services”, and the “Websites”), to protect our legitimate interests and for compliance with legal and regulatory obligations to which we are subject.

When you use our Services, you consent to the collection, storage, use, disclosure and other uses of your Personal Data as described in this Policy.

Personal Data

In the course of using the Services, we may ask you to provide us with certain Personal Data to provide and improve the Services, to contact or identify you, to enable you to access certain parts of the Websites, and as otherwise indicated in this Policy. We may collect the following Personal Data about you:

Non-Personal Data

We also collect data about the use of our Services and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data:

If you choose to use Amazon Alexa Skills or Google Assistant in connection with the Services, Amazon and Google will process your personal data via their voice processing technologies, by which they collect audio through the microphone on your device(s) to effectuate an instruction or request by you using Amazon Alexa Skills or Google Assistant. Please be aware that your use of Amazon Alexa Skills or Google Assistant may provide Amazon and Google with access to and use of information associated with your use of their device, including the audio you provide, and you should carefully review their privacy policy and terms of use (to learn more about their data processing, please visit Google's policies, here and here; and Amazon's policies here).
* If we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g. through a contact form.

When you visit or access our Services (including, without limitation, if you open an email we have delivered to you) we use (and authorize 3rd parties to use) pixels, cookies, events and other technologies. Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Websites’ performance, perform analytics and customize your experience on it. In addition, we may merge information we have with information collected through these tracking technologies with information we may obtain from other sources and, as a result, such information may become Personal Data.

To learn more about our Tracking Technologies please visit our Cookie Policy page.

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.

While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Services, and you do so at your own risk.

We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.

A. European Users' Rights

However, please note that these rights pertain to EU residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

Transfer of data outside the EEA 

EU users, please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

B.  California Residents

In the 12 preceding months, we have collected the above-mentioned categories of Personal Data from either of the following categories of sources:

The CCPA provides consumers with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.

Additionally, although clicking the “Do Not Sell My Personal Information” link will opt you out of the sale of your Personal Data for advertising purposes, it will not opt you out of the use of previously collected and sold Personal Data or all interest-based advertising. If you would like more information about how to opt-out of interest-based advertising in desktop and mobile browsers on a particular device, please visit https://optout.aboutads.info/ and https://optout.networkadvertising.org/. You may also download the AppChoices app at http://www.aboutads.info/appchoices to opt-out in connection with mobile apps, or use the platform controls on your mobile device to opt-out.

The request must:

If you have any general questions about the Personal Data that we collect about you how we use it, please contact us at [email protected] (please provide the required details as per Section 12 below). 

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

Requests Metrics

We publish metrics regarding the number of requests we have received, complied with (in whole or in part) or denied, and also the median number of days in which we responded to such requests, in the previous year, as applicable to the time period in which the CCPA was in effect. As of the date of publishing this Policy, such yearly data has yet to have been received. Once such data is received, it will be published in a dedicated Consumer Requests Metrics page which will be available within this Policy

C. Brazilian Residents

The following part of this Policy complements the general part of the Policy and addresses the specific disclosure requirements under the Brazilian Data Protection Law (Lei Geral de Proteção de Dados, "LGPD").

Processing of Personal Data

The processing of your Personal Data is not a condition for the use our Services. However, parts of our Services may not be available without registration and/or payment, which involve the processing of Personal Data.

Brazilian Users' Rights:

If you reside in Brazil, you have the following rights under LGPD:

Contact information: dpo@minutemedia.com (please provide the required details as per Section 12 below).

Under certain jurisdictions, some of the aforementioned rights may apply as well. Please contact us using the contact details provided below and we would make our best efforts to assist with any questions or requests.

We understand the importance of protecting children’s privacy, especially in an online environment. The Services are not designed for or directed at children under the age of 16 years old (“Minors”). We do not knowingly collect Personal Data from Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data, he or she should contact us using the details provided below.

This Policy is subject to changes from time to time, in our sole discretion. The most current version will always be posted on our Websites (as reflected in the "Last Updated" heading). You are advised to check for updates regularly. In the event of material changes, we may also provide you with a notice. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Privacy Policy.

Notwithstanding the forgoing, as of January 1st 2020, this Policy will be updated at least once every 12 months.

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) using the details provided below.

Kindly specify: (a) the nature of your request, (b) your country of residence, and (c) the name of the Services (website/product/application) subject of your request

Email: [email protected]