Privacy Policy

EFFECTIVE DATE: 01-03-2023

1. INTRODUCTION

You are reading Mea Platforms Group (bermuda) Ltd (“mea platforms”, “we” or “us”) privacy policy (“Policy”).

mea Platforms respects your privacy and is committed to protecting your Personal Data. This Policy will inform you as to how we look after your Personal Data when you contact us, when you do business with us, or when you otherwise engage with us, or we engage with you, including visiting the Website, using the mea Platforms Service via the Website or making enquiries of us or when we market our goods and services to you and tell you about your privacy rights and how the law protects you.

Please ensure that you read this Policy in conjunction with the mea platforms’ terms and conditions, as located at mea platforms Terms and Conditions.

2. DEFINITIONS AND INTERPRETATION

In this Policy, the following definitions are used:

Data: means, collectively, all information that you submit to mea platforms by means of the Website, or any other means, including, but not limited to, Personal Data and the Documentation. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Data Protection Laws: means any applicable law relating to the processing of Personal Data, including but not limited to the GDPR, the UK GDPR, privacy legislation applicable to the United States of America and any national or international implementing laws, regulations and secondary legislation;

Documentation: means any document that you upload to Website as part of the mea platforms Service, in accordance with the mea platforms Terms and Conditions and which might contain Personal Data;

General Data Protection Regulation (GDPR): means the General Data Protection Regulation ((EU) 2016/679) and the UK GDPR;

mea platforms Service: means the data ingestion services provided by mea platforms to you, made available via the Website and as provided in accordance with the mea platforms Terms and Conditions;

Personal Data: 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);

UK GDPR: means the UK European Union (Withdrawal) Act 2018 (as amended, including by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019);

Website: means the website that you are currently using, https://meaplatform.com and any sub-domains of this site unless expressly excluded by their own terms and conditions; and

You/your: means any third party that accesses the Website and is not either (i) employed by mea platforms and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to mea platforms and accessing the Website in connection with the provision of such services.

3. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Policy

This Policy aims to give you information on how mea platforms processes your Data when you interact with us, or when we interact with you.

This Privacy Policy is drafted in accordance with the principles of GDPR, however, notwithstanding this, nothing in this Privacy Policy is intended to override any consumer protection rights applicable in any geographical regions in which you are located, in accordance with which mea platforms shall continue to process the Member’s Personal Data.

Where you are accessing the Website from the United States of America, mea platforms will continue to process your Personal Data in accordance with the GDPR, subject to which you shall be granted the rights thereunder, as further detailed in clause 17 of this Privacy Policy.

It is important that you read this Policy together with any other policy or notice we may provide on specific occasions when we are processing Data about you so that you are fully aware of how and why we are using your Data.

This Policy was issued on November 22nd, 2021.

Children and minors

mea platforms does not knowingly collect or solicit Personal Data (as defined in clause 4) from children and minors. Anyone under the age of eighteen (18) will not be knowingly allowed to register for any service on the Website or to purchase any products or service on the Website.

If you are under eighteen (18), please do not attempt to register on the Website, upload any Documentation or send any Personal Data to us. This is information about yourself, including your name, e-mail or home address, house telephone number, mobile number or other contact details. No one under the age of eighteen (18) may provide any personal information to the Website or receive any services on mea platforms’ Website.

In the event that we become aware or informed that we have collected Personal Data from a child under the age of eighteen (18) without verification of parental consent, we will delete that information as quickly as possible.

Data protection role

If you are a customer of ours, mea platforms processes Personal Data in different ways when you use our products and services.

We act as a Data Controller when we process your Personal Data as a customer (or potential customer) when you visit the Website; sign up for a demo or a mea platforms event; reach out to our team.

We act as a Data Processor when we process the Personal Data of your end users who use or interact with your application that you’ve built on mea platforms’ platform. You can see a more detailed definition of the Personal Data we colled about your end users in our Data Protection Addendum, which is part of our agreement with you.

If you have any questions about this Policy, including any requests to exercise your legal rights, please contact mea platforms using the details set out below.

Contact details

Full name of legal entity: mea platforms group limited

Email address: legal@meaplatform.com

Physical address:

Mea Platforms Group (bermuda) Ltd

Canons Court, 22 Victoria Street

Hamilton

Bermuda

HM 12

Third-party links

Our 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 the Website, we encourage you to read the Policy of every website you visit.

4. THE DATA WE COLLECT ABOUT YOU

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, customer code or identifier, title, date of birth and gender.

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 or from other third parties.

Profile Data includes purchases or orders made by you, the nature of your business, your business interests, preferences, feedback and survey responses.

Usage Data includes information about how you use the Website, products and services.

KYC Data includes information about the source of funds you may use to purchase products or services from us, credit scores, reputation in the market, and other Data we require in order to verify your suitability as a client or supplier for us, and in deciding whether we may need some additional safeguards when doing business with you.

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 may be derived from your Personal Data but is not considered Personal Data in law as this Data does 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 or perhaps buying a certain type of product. 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 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. We ask that you not provide us with any Special Categories of Personal Data on or through the Website, or otherwise to us. If you provide us with any sensitive personal information to us when you use the Website, you must consent to our processing and use of such Special Categories of Personal Data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Website.

5. HOW IS YOUR PERSONAL DATA COLLECTED?

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

Direct interactions. You may give us your Identity, Contact and Financial Data by uploading the Documentation, 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;

meet with us either at our offices, your premises, or in other locations, and express an interest in our products or services;

create an account with us;

subscribe to any of our services or publications;

request marketing to be sent to you;

complete a survey; or

give us some feedback.

Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out below:

Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

Identity and Contact Data from Data brokers or aggregators including business directories.

Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU and the UK.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Website.

6. 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:

Where we need to perform or manage 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 override those interests.

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending third party direct marketing communications to you via email or text message or where you are an individual customer and we wish to send you marketing materials. You have the right to withdraw consent to marketing at any time by contacting us.

7. YOUR CONSENT

By submitting your information on the Website, which shall include, among other things, the uploading of any Documentation to the Website, you consent to the use of that information as set out in this Policy. If we change our Policy, we will post the changes on this page or on the Website and may place notices on other pages of the Website, so that you may be aware of the Personal Data we collect and how we use it at all times.

You agree that you do not object to us contacting you for any of the purposes of processing our services or your orders, statistical or survey purposes to improve this Website and its services to you, provision of Website content and advertisements to you, administration of this Website and where you consent, to notify you of services, products or special offers that may be of interest to you. You consent to such contact whether by telephone, e-mail or in writing and you confirm that you do not and will not consider any of the above as being a breach of any of your rights under any applicable Data Protection Laws.

8. 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.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your Data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

9. MARKETING

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing. We may also contact you if you are a business and you have not asked us not to contact you, and we believe you may be interested in our goods and services.

Third-party marketing

We will get your express opt-in consent before we share your Personal Data with any company outside our group of companies for marketing purposes.

Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Website/Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Policy.

Opting out

You can ask us or third parties to stop sending you marketing messages by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

10. CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

11. COOKIES

The Website may place and access certain ‘cookies’ on your computer, information about which can be found at our Cookie Policy available here.

12. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your Personal Data with third parties for the purposes set out in the table in clause 8 above. These include:

affiliates, such us our corporate parent, subsidiaries, and affiliates.

third party providers of Data and other services to us, such as credit agencies, and third party archival, cloud and backup providers;

advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

business and marketing partners, such us third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

third party providers of professional services, such as accountants, bankers, insurers and lawyers;

authorities and others, such as enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes;

third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Policy.

business transferees. We may disclose Personal Data in the context of actual or prospective business transactions (e.g., investments in mea platforms, financing of mea platforms, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of mea platforms as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

13. INTERNATIONAL TRANSFERS

We are headquartered in Bermuda and may use service providers that operate in other countries. Your Personal Data may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

We ensure your Personal Data is protected by requiring all our group companies to follow the same rules when processing your Personal Data.

Whenever we transfer your Personal Data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission or UK Government (as and where applicable) (from time to time).

We may use specific appropriate safeguards, which are designed to give Personal Data effectively the same protection it has in the EEA or the UK – for example, standard-form contracts approved by relevant authorise for this purpose.

In limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your Personal Data to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA or the UK.

14. DATA SECURITY

We employ a number of technical, organizational and physical safeguards designed to protect the Personal Data we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your Personal Data .

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

15. DATA RETENTION

How long will we use your Personal Data for?

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements to establish or defend legal claims, or for fraud prevention purposes.

To determine the appropriate retention period for Personal Data, we consider factors such as the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your Data: see clause 17 below for further information.

In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

16. REQUESTS

What we may need from you

Following any request made by you we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one (1) month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

17. YOUR LEGAL RIGHTS

You have the right to:

Be informed of how your Personal Data is being utilised by us, as set out in this Policy.

Request access to your Personal Data (commonly known as a “Data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate Data we hold about you corrected, though we may need to verify the accuracy of the new Data you provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the Data’s accuracy; (b) where our use of the Data is unlawful but you do not want us to erase it; (c) where you need us to hold the Data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your Data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. we will advise you if this is the case at the time you withdraw your consent.

No fee usually required to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

You may submit these requests by email to legal@meaplatform.com. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your Personal Data), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

18. COMPLAINTS

Should you be unsatisfied or you believe that your data is not being processed in accordance with the Data Protection Laws, you may contact mea platforms by email at help@meaplatform.com or alternatively, you may complain to the data protection regulator in your habitual place of residence:

• For UK residents: Information Commissioner’s Office (ICO). Further information, including contact details can be found on the ICO’s website at https://ico.org.uk/for-the-public/.

• For residents in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

19. GENERAL

You may not transfer any of your rights under this Policy to any other person. We may transfer our rights under this Policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Policy will be governed by and interpreted according to the law of England and Wales. All disputes arising under this Policy will be subject to the exclusive jurisdiction of the English and Welsh courts.

20. CHANGES TO THIS POLICY

mea platforms reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations.

You may contact mea platforms by email at legal@meaplatform.com