PRIVACY POLICY

This Website collects some Personal Data from its Users.

Mindlayers Ltd ("Owner", "we", "us", or "our") operates this website (hereinafter referred to as "Service").

Our Privacy Policy governs your visit to this website and explains how we collect, safeguard and disclose information that results from your use of our Service. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Our Terms and Conditions ("Terms") govern all use of our Service and together with the Privacy Policy constitute your agreement with us ("agreement").

This document can be printed for reference by using the print command in the settings of any browser.

DEFINITIONS AND LEGAL REFERENCES

Service – the website operated by Mindlayers Ltd.

This Website – The property that enables the provision of the Service.

Personal Data – data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data – data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

Cookies – small files stored on your device (computer or mobile device).

Data Controller – a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processors (or Service Providers) – any natural or legal juridical person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject – any living individual who is the subject of Personal Data.

User (or You) – the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

INFORMATION COLLECTION AND USE

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, Country, County, Postal code, City, Town, etc.
• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link in the received content.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through any device ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies: We use Session Cookies to operate our Service.
• Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
• Security Cookies: We use Security Cookies for security purposes.
• Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Other Data

While using our Service, we may also collect the following information where voluntarily provided: age, general location (country/region), and other data relevant to the provision of the programme and related communications.

In using the Website, you consent to the collection of data necessary to allow us to provide the services you require. If you object to the collection of data, you may not be able to use all or part of the services provided on this Website.

Use of Data

Mindlayers Ltd uses the collected data for various purposes:

• to provide and maintain our Service;
• to notify you about changes to our Service;
• to allow you to participate in interactive features of our Service when you choose to do so;
• to provide customer support;
• to gather analysis or valuable information so that we can improve our Service;
• to monitor the usage of our Service;
• to detect, prevent and address technical issues;
• to fulfil any other purpose for which you provide it;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including billing and collection;
• to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
• for any other purpose with your consent.

Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce legal agreements and policies. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Mindlayers Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Disclosure of Data

We may disclose personal information that we collect, or you provide:

• If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.
• To our subsidiaries and affiliates;
• To contractors, service providers, and other third parties we use to support our business;
• To fulfil the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information;
• With your consent in any other cases;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

Security of Data

The security of your data is important to us, but no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights Under GDPR

If you are a resident of the United Kingdom (UK) or the European Union, you have certain data protection rights under the General Data Protection Regulation (GDPR). We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at: [email protected].

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you;
• The right of rectification — to have your information corrected if it is inaccurate or incomplete;
• The right to object to our processing of your Personal Data;
• The right to restriction — to request that we restrict the processing of your personal information;
• The right to data portability — to receive your Personal Data in a structured, machine-readable format;
• The right to withdraw consent at any time where we rely on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact the Information Commissioner's Office (ICO) in the United Kingdom.

Our Policy on "Do Not Track" Signals

This Website does not support "Do Not Track" requests. To determine whether any of the third-party services it uses honour the "Do Not Track" requests, please read their privacy policies.

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

Behavioural Remarketing

We may use remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

Payments

We provide paid products and services within the Service. Payment processing is handled by authorised third-party processors including Stripe, PayPal and Klarna. We will not store or collect your payment card details. That information is provided directly to the relevant payment processor, whose use of your personal information is governed by their own Privacy Policy. These processors comply with the standards set by PCI-DSS as managed by the PCI Security Standards Council.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Services are not intended for use by minors or those under the age of 18 (depending on your jurisdiction). We do not knowingly collect personally identifiable information from minors. If you become aware that a child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from a child without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the bottom of this document. You are advised to review this Privacy Policy periodically for any changes.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at: [email protected].

POLICY SUMMARY

Personal Data collected for the following purposes and using the following services:

Analytics

Facebook Ads Conversion Tracking (Facebook Pixel)
Personal Data: Cookies, Usage Data

Google Analytics
Personal Data: Cookies, Usage Data

Hyros
Personal Data: Cookies, Usage Data

Advertising

Facebook Lookalike Audience
Personal Data: Cookies, Usage Data

Google Ads / Google Ads Similar Audiences
Personal Data: Cookies, Usage Data

Tracking Pixels

Facebook Pixel
Personal Data: Cookies

TikTok Pixel
Personal Data: Cookies

Google Tag Manager
Personal Data: Cookies, Usage Data

CRM and User Database Management

GoHighLevel
Personal Data: Cookies, Email address, Various types of Data as specified in the privacy policy of the service

Payment Processing

Stripe
Personal Data: Various types of Data as specified in the privacy policy of the service

PayPal
Personal Data: Various types of Data as specified in the privacy policy of the service

Klarna
Personal Data: Various types of Data as specified in the privacy policy of the service

Remarketing and Behavioural Targeting

Facebook Custom Audience
Personal Data: Cookies, Email address

Google Ads Remarketing
Personal Data: Cookies, Usage Data

FULL POLICY

Types of Data Collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name; last name; country; data communicated while using the service. Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using this Website. Any use of Cookies or other tracking tools by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in this document and in the Cookie Policy.

Methods of Processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. The Data processing is carried out using computers and/or IT-enabled tools, following organisational procedures and modes strictly related to the purposes indicated.

Legal Basis of Processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

Retention Time

Personal Data shall be processed and stored for as long as required by the purpose for which it was collected. Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed. Once the retention period expires, Personal Data shall be deleted.

Detailed Information on the Processing of Personal Data

Advertising

This type of service allows User Data to be utilised for advertising communication purposes, possibly based on User interests. Some services listed below may use Trackers to identify Users or employ behavioural retargeting techniques.

Facebook Lookalike Audience

Facebook Lookalike Audience is a behavioural targeting service provided by Meta Platforms that uses Data collected through Facebook Custom Audience to display ads to Users who exhibit similar behaviour to those in a Custom Audience list. Users can opt out of Meta's use of cookies for ad personalisation by visiting https://www.aboutads.info/choices/.

Google Ads / Google Ads Similar Audiences

Google Ads and Google Ads Similar Audiences are advertising and behavioural targeting services provided by Google that use data to display personalised ads to Users. Users can opt out by visiting Google Ad Settings.

Analytics

Facebook Ads Conversion Tracking (Facebook Pixel)

The Facebook Pixel connects data from Meta's advertising network with actions performed on this Website, enabling conversion tracking attributable to ads on Facebook, Instagram and Audience Network.

Google Analytics

Google Analytics tracks and reports website traffic to analyse User behaviour and improve the service. Google may use the collected Data to contextualise and personalise ads on its advertising network.

Hyros

Hyros tracks and analyses the effectiveness of various marketing channels such as email, paid ads and organic traffic to optimise campaigns and improve marketing decisions.

Additional Tracking Pixels

TikTok Pixel

Monitors User behaviour after interacting with TikTok ads, used to measure campaign effectiveness and build targeted audiences. Users may manage their TikTok ad preferences via their TikTok account settings.

Google Tag Manager

Simplifies the implementation and management of tracking tags on the Website without requiring code changes.

CRM and User Database Management

GoHighLevel

GoHighLevel is a CRM and marketing automation platform used to manage interactions with Users. It collects and processes Personal Data such as contact information to manage customer communications, send automated messages, and track interactions across multiple channels (SMS, email, phone calls).

Payment Processing

Payment transactions on this Website are processed by authorised third-party payment processors. These processors comply with PCI-DSS standards. We do not store or collect payment card details directly.

Stripe

Stripe is a payment processing service provided by Stripe, Inc. or Stripe Payments Europe Ltd. Stripe processes card payments securely and may use data for fraud prevention. Privacy policy: https://stripe.com/privacy.

PayPal

PayPal is a payment processing service provided by PayPal Inc. or PayPal (Europe) S.à r.l. et Cie, S.C.A. Privacy policy: https://www.paypal.com/privacy.

Klarna

Klarna is a buy-now-pay-later payment service provided by Klarna Bank AB. Klarna may use data to facilitate payment processing, assess creditworthiness and prevent fraud. Privacy policy: https://www.klarna.com/privacy.

Remarketing and Behavioural Targeting

Facebook Custom Audience

Facebook Custom Audience is a remarketing service that connects the activity on this Website with Meta's advertising network. Users can opt out by visiting https://www.aboutads.info/choices/.

Google Ads Remarketing

Google Ads Remarketing connects activity on this Website with Google's advertising network to display targeted ads. Users can opt out by visiting Google Ads Settings.

Further Information about Personal Data

Selling goods and services online

The Personal Data collected are used to provide the User with services online, including the processing of purchases and the dispatch of physical goods (where applicable). The kind of Data collected depends on the payment system used.

The Rights of Users

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to: withdraw their consent at any time; object to processing of their Data; access their Data; verify and seek rectification of their Data; restrict the processing of their Data; have their Personal Data deleted or otherwise removed; receive their Data and have it transferred to another controller; and lodge a complaint with their competent data protection authority.

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

This Website uses Trackers. To learn more, the User may consult the Cookie Policy.

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) and use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time by contacting [email protected].

Contact Information

Owner and Data Controller:
Mindlayers Ltd, company number 16090721
35-37 Ludgate Hill, Office 7, London, England, EC4M 7JN
[email protected]

Legal information

This statement relates solely to this Website, if not stated otherwise within this document.

Effective Date: April 13, 2025