privacy policy

We appreciate your interest in our Privacy Policy. At Mentor Mira, we take the protection of your data very seriously, and in the below, we explain what data we collect when you use our website and services and how it is used.

General Information

• What law applies?
  Our use of your Personal Data is subject to both the UK`s Data Protection Act (“DPA”) and the EU's General Data Protection Regulation (“GDPR”), and of course, we process your Personal Data accordingly.
• What is Personal Data?
  Personal Data is any information relating to personal or material circumstances that relates to an individual. This may include a name, date of birth, e-mail address, postal address, or telephone number but also online identifiers such as IP addresses or device ID`s.
• What is processing?
  "Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
• Who is responsible for data processing?
  The responsible party within the meaning of the DPA and the GDPR is Mentor Mira of 8 Lowther House Churchill Gardens SW1V 3BD London. If you have any questions or if you wish to exercise your rights, please contact us using mira@mentormira.com, or use our Contact Form.
• What are the legal bases of processing?
  In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data:
• For the fulfilment of contractual obligations
  The purposes of the data processing are primarily based on the service we provide.
• Within the framework of our legitimate interests
  Where necessary, we process your data beyond the actual performance of the contract in order to safeguard legitimate interests of us or third parties. Examples are:
  Ensuring IT security and IT operations, Measures for business management and further development of our services, Defence against third-party claims and enforcement of own claims.
• Based on your consent
  In so far as you have given us your consent to process personal data for certain purposes.
• Is there an obligation for me to provide data?
  Within the scope of our business relationship, you are only required to provide personal data that is necessary for the establishment, implementation, and termination of a business relationship or that we are legally obliged to collect. Without this data, we will usually have to refuse to conclude the contract or will no longer be able to perform an existing contract and may have to terminate it.

Data we collect automatically

• Log data
  Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user's device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.
• Content Delivery Network
  We use a Content Delivery Network (CDN) to distribute our online content. Our CDN is a network of regionally distributed servers of our technical service providers connected via the Internet. When our website is visited, your device`s browser transmits information to these service providers, which is collected in corresponding server log files. Server log files are generally anonymised and then transmitted without any personal reference. Server log files include, in particular, i) details of the browser and operating system used, ii) the previously visited pages (so-called referral URL), iii) the IP address of the device used, iv) the name of the Internet provider, as well as v) the date, time of all page views including the amount of data transmitted. The legal basis for processing is our legitimate interest.
• Hosting
  To provide our website, we use the services of A2 Hosting, Inc, who processes all data to be processed in connection with the operation of this website, including log files on our behalf. The legal basis is our legitimate interest.
• Use of cookies
  We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: a) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and b) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).

As set out in the UK`s Privacy and Electronic Communications Regulations (“PECR”), and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies and do so when you visit our website for the first time using the Cookie Consent Management Tool operated by CookieYes Limited. For further information on the Cookies we use, please refer to our Cookie Policy.

Data we collect directly

• Contacting us
  In addition to your name, company name, and e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and contract.
  We are present on social media (currently, Facebook, LinkedIn, Twitter, Instagram, Pinterest, and YouTube) based on our legitimate interests. If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any.
• When using our services
  We process the Personal Data involved in your use of our services in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.
• Administration, financial accounting, office organisation, contact management
  We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
• Payment Data
  If you pay through our website your payment data will be processed via our payment service provider SureCart. Payment data will solely be processed through SureCart and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the service.
• Newsletter
  If you have consented to receive our newsletter, we will use your email address and, if applicable, your name to send you information about us, our books and publications, promotions, and news. You can revoke your consent to receive the newsletter or to the creation of personalised user profiles at any time with effect for the future. You will find the unsubscribe link at the end of each newsletter. The revocation leads to the deletion of the collected user data.

Data processing through integration of third-party services and content

We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services ("content").

This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any,

• Analytics and Tracking: Google Analytics by Google LLC,
• Fonts: Google Font API by Google LLC,
• Content Management System (CMS): WordPress by Automattic Inc,
• Spam protection: reCAPTCHA by Google LLC, and
• Forms: WP Forms by WPForms, LLC.

General Principles

• Who receives my data?
  Within Mentor Mira, those that need your data to fulfil our contractual and legal obligations will receive access to it.
  Processors used by us may also receive data for these purposes. These are companies in the categories of IT services, telecommunications, and sales and marketing. Where we use processors to provide our services, we take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of personal data in accordance with the relevant legal provisions.
  Data is only passed on to third parties within the framework of legal requirements. We only pass on users' data to third parties if this is necessary, for example, for contractual purposes or on the basis of legitimate interests in the economic and effective operation of our business or you have consented to the transfer of data.
• How long will my data be stored?
  As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.
  In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods and HMRC, among others. The retention and documentation periods specified there are up to 6 years.
• How do we secure your data?
  Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of content or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.
  Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
• Are data transferred to a third country or to an international organisation?
  Your data is not transferred to third countries (countries outside the UK and the EEA).
• Special Category Data
  Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.
• Minors
  We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.
• Automated decision-making
  Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.
• Do Not Sell
  We do not sell your Personal Data.

Your Rights and Privileges 

• Privacy rights 
  Under the DPA and GDPR, you can exercise the following rights:
  • Right to information
  • Right to rectification
  • Right to object to processing
  • Right to deletion
  • Right to data portability
  • Right of objection
  • Right to withdraw consent
  • Right to complain to a supervisory authority
  • Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

• Updating your information
  If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
• Withdrawing your consent
  You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
• Access Request
  In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
• Complaint to a supervisory authority
  You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection.

Validity and questions

This Privacy Policy was last updated on Friday, 07 April 2023, and is the current and valid version. However, we want to point out that from time to time due to actual or legal changes a revision to this policy may be necessary. If you have any data protection questions, please feel free to contact us.