Mifu Privacy Policy

Welcome to MIFU LTD's privacy policy. MIFU LTD respects your privacy and is committed to protecting your personal data. This privacy policy will inform you of how we collect, use and protect your personal data when you visit our website (regardless of where you visit it from), and tell you about your privacy rights under UK law.

Purpose of this privacy policy

This privacy policy is designed to give you information on how MIFU LTD collects and processes your personal data through your use of this website, including any data you may provide through this website when you interact with any Mifu Ltd website, app, email or other.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any notices or privacy policies which we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and policies and is not intended to override them.

Controller

MIFU LTD is the controller and responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact mark@mifu.co.uk.

You have the right to make a complaint to the Information Commissioner's Office (ICO), the UK regulator for data protection issues, at any time. We would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, date of birth and gender, interests, social media presences.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Social Data includes any data you have made publicly available through any social media platform. Including, but not limited to, username, biography, profile picture, metadata, posts, captions.
• 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, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

Through this Privacy Policy, we satisfy our responsibilities under GDPR Articles 13 and 14 to inform data subjects about how their data is processed. NOTE: There may be instances where we cannot individually notify each data subject (notably Influencers) of this, especially when we collect data from third-party sources like social networks.

As per Recital 62 and Article 14(5)(b) of the GDPR, we are permitted to do so when notifying each Influencer would be impractical or require undue effort, especially in the context of statistical processing.

However, we are committed to taking suitable steps to safeguard the rights, freedoms, and legitimate interests of data subjects.

We use different methods to collect data from and about you including through:

1. Direct interactions

You may give us your Identity, Contact, Financial and Social Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services
• create an account on our website
• subscribe to our service or publications
• request marketing to be sent to you
• enter a competition, promotion or survey
• give us feedback or contact us

2. Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

3. Third parties or publicly available sources

We will receive personal data about you from various third parties and public sources as set out below:

• Social and Technical Data from analytics providers such as Google based outside the UK, advertising networks, search information providers, and social media networks such as Meta and TikTok
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe
• Identity and contact data from data brokers or aggregators
• Identity and contact data from publicly available sources such as social media networks

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• We will perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not conflict with each other.
• Where we need to comply with a legal obligation.
• To provide you with opportunities in your interest.

We generally do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you. You have the right to withdraw consent at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Brands

Influencers

We only handle data that you've publicly posted on social media platforms such as Instagram, YouTube, TikTok, and Twitch. We manage your personal information in strict compliance with applicable laws, particularly adhering to the principles of "lawfulness, fairness, transparency" as outlined in Article 5(1)(a) of the GDPR, and we respect your rights, as detailed in the subsequent section.

Automatic Processing

Audience Statistics and Data

We examine a large volume of data to furnish Clients with relevant statistics. Specifically, we analyze the Influencer audience's gender, age group, and ethnicity. While these categories could be viewed as sensitive, we've conducted an assessment as outlined in Article 35(7)(a) of the GDPR to confirm our legitimate interests and to ensure they don't infringe upon the basic rights and freedoms of the Audience or any individuals (Article 6(1)(f) GDPR). We've determined that our statistical processing complies with the applicable laws and doesn't violate individual rights.

To lawfully handle data concerning the Audience's ethnicity, we rely on appropriate legal grounds. One such basis is statistical processing (Article 9(2)(j) GDPR), which safeguards the fundamental rights and interests of the Audience. Additionally, this data is publicly shared by the data subjects themselves (Article 9(2)(e) GDPR). This data handling neither discriminates against nor adversely affects any individuals. Furthermore, there is no automated decision-making or profiling based on the ethnicity of the Audience (Article 14(2)(g) GDPR).

Our legitimate interest to work with personal data are direct marketing purposes as said in Recital 47 GDPR (EU GDPR), and Statistical purposes referring to Recitals 113 and 162 GDPR.

Option Holders and Share Plan Participants

If you are granted share options under the Mifu Ltd Enterprise Management Incentive ("EMI") scheme or any other employee share plan operated by the Company, we will collect, use, and share certain personal data about you in order to establish, operate, and administer that plan.

Types of personal data

We may collect and process the following categories of data in connection with the share plan:

• Identity data (e.g., name, date of birth, national insurance number);
• Contact data (e.g., home address, email address, telephone number);
• Employment data (e.g., job title, department, employment start date, status);
• Share plan data (e.g., number and type of options granted, vesting and exercise dates, exercise price, and option exercise details);
• Tax and financial data (e.g., payroll information, tax references, bank details for payments or reimbursements);
• Correspondence and documentation relating to your option grant, exercise, or participation in the plan.

Purpose and legal basis for processing

We process this personal data for the following purposes:

• To establish and administer your participation in the share plan (including option grants, vesting, exercises, and record-keeping);
• To comply with our legal and regulatory obligations, including reporting to HMRC and maintaining statutory company records;
• To communicate with you and maintain accurate internal records regarding your shareholdings and entitlements.

The legal bases for processing are:

• Performance of a contract (your option agreement and share plan participation);
• Compliance with legal obligations, including those under tax, employment, and company law;
• Our legitimate interests in operating and managing the share plan efficiently and transparently.

Disclosure and sharing

We may share limited personal data relating to your participation in the share plan with:

• Professional advisers (e.g., lawyers, accountants, tax advisers);
• Share plan administrators, registrars, or cap table management providers;
• HM Revenue & Customs (HMRC) and other regulators, as required by law.

Where we use external administrators or technology platforms (e.g., for maintaining option registers or handling exercises), these providers act as data processors on our behalf under appropriate contractual safeguards.

Data retention

We retain your share plan data for as long as is necessary to administer your participation and comply with our legal obligations (including statutory tax and corporate record-keeping requirements, which may extend up to seven years after the end of your participation).

Your rights

You have the same rights in respect of your personal data under the share plan as set out elsewhere in this privacy policy, including the rights of access, rectification, restriction, and erasure (subject to applicable legal limitations).

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a privacy centre where you can view and make certain decisions about your privacy.

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