Privacy policies are the most ignored part of any website. In fact, companies could recite the lyrics of a Spice Girls song in their policies, and no one (but lawyers) would notice.
Like most people, when you use the internet privately – on your smartphone or desktop – you probably have the impression that your activities are also private. But the truth is that you are more exposed than you think.
At Mine, we believe privacy policies should help you understand how your Personal Data is being used and provide you with a fair choice to control it.
Sharing Personal Data with us is entirely up to you.
By law, you don’t have to provide us with any Personal Data, but if you do, you can withdraw your consent at any time, and we will remove your account and all Personal Data associated with it.
You can always request from us to review, amend, delete, or restrict the processing of your Personal Data. How? There’s a one-click button in your “Profile” section to delete or to get a copy of your Personal Data. You can also send us a direct request here.
How do we use your Personal Data?
We use your Personal Data for three reasons: 1) to provide you with our services; 2) to ensure that our services are working properly and prevent attempts to break in our systems or use your Personal Data improperly; 3) where there is a legal obligation imposed on us, or to protect legal rights.
Children under the age of 16 are not permitted to use our services.
If you are under 16 years old, we will need your parents’ or guardian’s consent. We’re sorry, but if you are under 16, you’ll have to sit tight just a little longer to use our service without their approval.
What happens when you register for our service?
Your email inbox reflects most of your digital footprint, Mine has developed a non-intrusive technology that reconstructs that footprint while collecting the bare minimum of data.
When you register to our service, we will ask you to provide us your permission to connect to your email inbox. We use methods such as “Connect with Google”, “Connect with Yahoo”, and “Connect with Microsoft” to securely access your email inbox. These methods are based on the OAUTH2 secured authorization protocol, which means we don’t have any access to your password.
Then, we will identify email exchanges between you and the digital services you interacted with (for simplicity - we call them “companies”) and present you with the list of these companies. Our technology scans only:
the subject lines of the messages;
the email’s snippets - the first few words of the email, as presented on your email inbox’s main page;
the email’s metadata - details that are not part of the email body, such as the sender address and the email date.
During this process, we do not process or collect the content of any email in your inbox.
Now that you can access your digital footprint, you can exercise your legal rights and send reclaim requests (right-to-be-forgotten) to the companies of your choice. Every time you decide to reclaim your Personal Data from a company, the request is transmitted directly from your email inbox. We help you send these requests, but we do not act as an agent on your behalf.
To help you complete your reclaim requests faster and save you precious time, your requests will include the original subject lines of the last three email messages that you received from the company. These will serve as evidence for the company that it holds your Personal Data.
In some cases, deleting your Personal Data is not a one-click process. In other cases, companies will reach out to you to further verify your identity or ask for additional information. To make the deletion process more comfortable, you can view the responses and reply to the companies directly from Mine’s app. We will access and reflect the relevant email thread to you in real-time. We don’t collect any of these email messages, your email messages remain in your own inbox.
We do not sell, trade or rent your Personal Data.
We will never sell, trade or rent your Personal Data, for any purpose. We only share Personal Data with third parties in connection with the provision of the services to our users, for example, cloud environment, customer support, and web analytics. When you send a reclaim request to a certain company, we will share with that company the evidence to the fact that they hold your Personal Data. This evidence is the subject lines of the last three email messages that the company has sent. Please note that most likely that the company already has this information since it retains copies of the messages sent to you. We share this evidence only so the company can verify and fulfill your request faster.
We safeguard and secure your personal data.
We have built our technology infrastructure and AI on privacy-by-design principals that have gone through a strict external security assessment. We treat your Personal Data as we treat our own data – with great care. We invest resources, deploy measures, and follow procedures to provide a safe and secure environment for your Personal Data.
[fs-toc-omit]What types of data does Mine collect and for what purposes?
Mine collects personal and non-Personal Data. Let’s start by explaining important terminology: Definitions:
"Personal Data" means information that identifies or can identify an individual, such as first and last name, email address, profile picture, unique online identifiers, etc.
"Non-Personal Data", means information, usually on an aggregated form, that cannot be linked to a single identifiable individual, taking in mind all means reasonably likely to be used by Mine or by any other person to identify that individual, directly or indirectly.
Personal Data Collected and Processed by Mine
We process and collect Personal Data for the following purposes:
Type of Personal Data - Personal Data provided by you during registration and creation of your user's account. Full Name, Email Address, and Email Token.
Purpose of processing - We process this type of Personal Data to provide, manage, and control our services to you, including to maintain contact with you and to provide you with customer service and support.
Type of Personal Data - Personal Data processed during the discovery of your digital footprint from email messages in your inbox. The metadata that we process include:\
the subject line of the emails;
the sender’s email address;
the date of the first email message received from the company;
the date of the last email received from the company with the service;
the existence of attachments to the email message (we do not access the attachments themselves. We will only know whether a file was attached or not); and
the first line of the email message as presented in your inbox, which means a snippet of the email message as shown in the main page of your inbox.
We don’t process or collect the content of any email message in your inbox during this process. However, to make the deletion request process more comfortable, you can view the responses and reply to the companies directly from Mine’s app. We will access and reflect the relevant email thread in real-time. We don't collect any of these email messages, your email messages remain in your own inbox. In some cases, we may use the specific interactions between you and the companies with regard to your deletion requests (in a redacted form without any personal data) to train our personal data assistant, so we can provide you with better suggested answers. This will help you complete your deletion requests faster.
Purpose of processing - We use this type of Personal Data to perform our duties and obligations to you under the contract between us, including to provide you with our services.
Type of Personal data - Analytics data regarding the use of our website and app - using tracking technologies (see our 3rd-party list here), which collect, for example, your internet protocol (IP) address, and technical data transmitted by the device that you are using such as your browser type, operating system type, device type, preferred language, the path you have taken in our website, the content you have interacted with, the time and date of your session, directing URLs and general geolocation (such as country).
Purpose of processing - We process this type of data to operate and improve our services.
Purpose of processing - We process these types of Personal Data to support our legitimate business interests, for example, to operate, protect, and improve the website and our services, their content, and how we offer them; for auditing and tracking usage statistics and traffic flow.
Purposes relevant to all types of data – We use all types of data that we receive, collect to support our legitimate business purposes, including – to protect our services from illegal, fraudulent (such as identity theft), abusive and malicious activities on our website and service; to handle inquiries and complaints, to resolve disputes and to protect legal rights; to support requirements from us under the law, for example, for tax and auditing purposes; and to comply with court orders, warrants and requirements to assist law enforcement agencies.
Special Categories of Personal Data
“Special Categories of Personal Data”, means any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person's health, or data concerning a person’s sex life or sexual orientation. We do not intentionally collect any data which constitutes Special Categories of Personal Data and we urge you not to share with us any Personal Data of this type.
Non-Personal Data Processed by Mine
We collect non-personal data about the use of our website and the services, such as the scope of use, frequency, latency, pages accessed and viewed, interactions with content and materials displayed, and other technical information regarding the type of devices used to access our services.
Non-Personal Data is used mainly for clickstream analysis, to maintain and develop our website and services, to measure and understand the level of engagement with the services, for general business analytics for ensuring the technical functioning of our network, to help prevent fraudulent use of our services, to protect the website and our services from cyber threats and for developing new capabilities and features.
Cookies are small files that a web server sends to a user's device when the user browses online.
Your device removes session cookies when you close your browser session. Persistent cookies last for longer periods. You can view the expiry date of each cookie, through your browser settings.
We use both types. We use persistent cookies to remember your log-in details and make it easier for you to log-in the next time you access our website and application. We use this type of cookies and session cookies for additional purposes, such as operating, protecting, and improving the website and our services, their content and how we offer them or for auditing and tracking usage statistics and traffic flow to facilitate the use of our services’ features and tools.
Every browser allows you to manage your cookies preferences. You can block or remove certain cookies, or all of them through your browser settings. Please bear in mind that blocking or removing cookies will have an effect on your user experience with our service. For example, you will need to re-enter your log-in details, or even prevent you from using features of the service.
[fs-toc-omit]Will Mine share Personal Data with Third parties?
Mine shares Personal Data with several service providers, with a single purpose of providing the best service to our customers. See the full list here. We will never sell, trade or rent your personal data to anyone. Not now, not ever!
Other than the third parties described above, we share Personal Data only under the following limited circumstances:
With companies you engaged with online and wish to instruct them to delete your Personal Data. When you request the erasure of your Personal Data from a company, the erasure request will be sent directly from your account with the relevant information to support it and to support the authentication of your identity.
With third parties if necessary to comply with applicable law, a legal or regulatory requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases and our services, to take precautions against legal liability, to enforce our agreements and policies, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.
We may share non-Personal Data, aggregated, statistical, and anonymized data for lawful and legitimate business purposes without limitation.
Personal data control
[fs-toc-omit]How Can I Control My Personal Data Processed or Collected by Mine?
We respect your Personal Data and treat it as our own, with great care. It is yours to manage and therefore we made it very easy for you to control it through a click of a button, inside your profile page within the app. In addition, you can always contact us directly here. We make efforts to accommodate individuals’ rights under various laws and regulations. However, not all of them apply to us and to your use of our website and services. If you want to exercise a right that is not covered by our policy and believe that we need to comply with your request, you are welcome to contact us here.
Access Your Personal Data. You may review your Personal Data collected by Mine by accessing your profile page. You may also contact us here.
Delete or Restrict the Processing of Your Personal Data. You may request the deletion or the restriction of processing of your Personal Data directly from your profile page. You may also contact us here.
Withdraw your consent. At any time, you may withdraw your consent to us. We will stop the processing of your Personal Data that is governed by consent. Note, that withdrawing consent may mean that your account will be removed, and you will no longer be able to use Mine.
Unsubscribe. At any time, you can request that we will not send you our newsletter and marketing material. It will usually take a few days to remove your details from our distribution list. You can manage your email preferences from your profile page. You may also contact us here.
Migrate your Personal Data From our Service. To the extent relevant to you and to our services, and mandated by applicable law, you may request the transfer of your Personal Data from our service elsewhere.
Filing a complaint to the authorities. You are entitled to file a complaint with the applicable privacy or data protection regulator in connection with concerns you may have about your privacy and Personal Data.
If you contact us and request to exercise any of the rights detailed above, we may request that you provide us with certain information in order to verify your identity and locate your Personal Data.
We will make our best efforts to enable you to exercise your rights as soon as possible and no later than required under applicable laws, unless we need to extend such period, in accordance with applicable laws. In such a case, we will inform you about the extension period and explain the reasons for the delay.
We retain your Personal Data as long as you are a user of our services. When you decide to delete your account, or if we need to remove your account, we will delete your Personal Data from our databases within 30 days, following the termination of your Mine account or agreement with us, and within 60 days from all backups.
We may need to retain certain details for longer periods of time to comply with legal, tax, and accounting requirements, or if we believe that these details are necessary for current or expected legal proceedings. We make efforts to keep the retained data to the minimum necessary and for periods no longer than required.
Non-Personal Data, statistical, or anonymized data is retained by us without limitation of time.
Security of Data
We use physical, technical, and administrative security measures for the services that we believe comply with applicable laws and industry standards. These measures are designed to help us prevent your Personal Data from being accessed without proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost.
Please bear in mind that the transmission of information via the internet cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we, like anyone else, cannot fully guarantee the security of data transmitted via our website or our services.
If a data incident that involves your Personal Data occurs, we will take maximum efforts to contain the incident, minimize the risks to the extent possible and, if required by applicable laws, provide you with a notification about the incident.
Transfer of personal data
[fs-toc-omit]Will Mine transfer Personal Data internationally?
We keep your Personal Data on servers located in the European Union. However, we use service providers, such as our customer support service, who need to use certain Personal Data to help us provide you with our services. They keep the data in other countries, as well, including in the United States.
When you send reclaim requests (right-to-be-forgotten) to certain companies, we will include within the request evidence that these companies hold your Personal Data (the subject line and metadata of the last 3 email messages that the company has sent you). That evidence is crucial to streamline your request and save you the trouble of back and forth messages with them.
These data transfers are necessary to perform our services to you, and to perform our contracts with third parties that serve your interest to receive an efficient platform for exercising your rights.
If laws that apply to the transfer of your Personal Data under this policy, require us to provide further details about the destination of your Personal Data and your consent to the transfer, then please note that these companies may keep their data in various countries and that the data protection rules may be different than those in your country of residence.
Your consent to this policy means that you also explicitly consent to such data transfer.
Persons under 16
Our services are not intended for users under the age of 16. Children under the age of 16 are not permitted to use the Services nor provide us with any Personal Data without the consent of a parent or guardian.
Changes and updates
Substantial changes will take effect 30 days after they are posted. Other changes will take effect within 7 days. Please note that changes in laws and regulations may require us to modify this policy within shorter periods of time.
If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at -
Say Mine Technologies Ltd.
23 Derech Menachem Begin, Tel Aviv-Yafo, 6618356 Israel