Privacy Policy

(Personal Data Processing Policy)

1. General Provisions

1.1. This Personal Data Processing Policy (hereinafter — the "Policy") has been developed in accordance with applicable data protection legislation (including the UK GDPR and the Data Protection Act 2018) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data carried out by IMAGENIC LTD (company number 13950150, registered office: 71-75 Shelton Street, London, United Kingdom, WC2H 9JQ) (hereinafter — the "Operator").

1.2. The Policy applies to all information that the Operator may obtain about users of the website https://mira.team (hereinafter — the "Website") and the "Mira" mobile application (hereinafter — the "Application").

1.3. Use of the Website and the Application constitutes acknowledgement of this Policy.

2. Legal Grounds for Processing Personal Data

Personal data is processed on the following legal bases:

• The consent of the data subject (Article 6(1)(a) of the UK GDPR);

• The necessity of performing a contract to which the data subject is a party (Article 6(1)(b) of the UK GDPR);

• Compliance with legal obligations imposed on the Operator under applicable law (Article 6(1)(c) of the UK GDPR).

3. Categories and List of Personal Data

3.1. The Operator may process the following personal data:

3.1.1. Data provided by the user:

• Email address;

• Surname, first name, and (where provided) middle/patronymic name;

• Username/alias;

• Data provided in feedback forms;

• Data submitted via the manufacturer form (name of the legal entity or sole trader, tax/registration number, address, product information, full name and position of the contact person, email, telephone).

3.1.2. Data generated through use of the Application:

• Product scanning history;

• Barcodes (EAN, QR, etc.) not linked to the user.

3.1.3. Data collected automatically:

• IP address;

• Cookie data;

• Browser and device information;

• Operating system version;

• Language settings;

• Crash data and technical logs;

• Service usage statistics.

3.2. User-generated content, including product photographs, may be published on the Website and within the Application. Such content is not linked to the User's identity and is not considered personal data.

4. Purposes of Personal Data Processing

Personal data is processed for the following purposes:

• Registration and identification of users;

• Provision of Website and Application functionality;

• Handling of enquiries and applications (including manufacturer applications);

• Feedback;

• Improvement of service quality;

• Analytics and usage statistics;

• Compliance with applicable legal requirements.

5. Operations Performed with Personal Data

The Operator performs the following operations: collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), anonymisation, blocking, deletion, and destruction of personal data.

6. Cookies and Similar Technologies

6.1. The Website uses cookies and similar technologies for the following purposes:

• Authorisation and saving of user preferences;

• Collection of anonymous statistics (e.g., Google Analytics and similar tools).

6.2. The User may disable cookies in their browser settings; however, this may limit the functionality of the Website.

6.3. Cookies containing user identifiers are used only with the User's consent and solely for the purposes set out in this Policy.

7. Conditions of Processing and Transfer to Third Parties

7.1. Personal data is not transferred to third parties, except in the following cases:

• Where required by applicable law;

• Transfers to contractors (hosting providers, analytics services, and technical support providers), provided they comply with confidentiality requirements;

• Other cases with the consent of the data subject.

7.2. When using analytics services, cross-border (international) transfers of data may occur in accordance with the requirements of Articles 44–49 of the UK GDPR.

8. Data Storage Location

The Operator stores personal data on servers located within jurisdictions that ensure an adequate level of data protection in accordance with applicable UK data protection law. Where international transfers are necessary, the Operator ensures appropriate safeguards are in place.

9. Personal Data Retention Periods

Personal data is processed and stored for no longer than is necessary for the purposes of processing, unless a different retention period is required by applicable law.

Upon achievement of the processing purposes or withdrawal of consent, personal data shall be destroyed or anonymised.

10. Rights of the Data Subject

The data subject has the right to:

• Obtain information about the processing of their personal data (right of access);

• Request the rectification, restriction, or erasure of personal data;

• Withdraw consent to processing;

• Object to processing and request data portability;

• Lodge a complaint with the competent supervisory authority (the Information Commissioner's Office, ICO) or seek a judicial remedy.

Requests may be sent to the Operator's registered address or by email to: hi@mira.team.

11. Personal Data Protection Measures

The Operator implements the necessary legal, organisational, and technical measures to protect personal data in accordance with:

• The UK GDPR (in particular, Article 32 — Security of processing);

• The Data Protection Act 2018;

• Industry-recognised information security standards.

12. Processing of Minors' Data

The service is not intended for persons under the age of 12. The processing of minors' data is carried out only with the consent of a legal representative.

13. Changes to the Policy

The Operator reserves the right to make changes to this Policy. The current version is published on the Website.

Date of last update: 12 February 2026