This Privacy Policy describes Our policies and procedures on the collection, use and
disclosure of Your information when You use the Service and tells You about Your
privacy rights and how the law protects You. We use Your Personal data to provide and
improve the Service. By using the Service, You agree to the collection and use of
information in accordance with this Privacy Policy.
 
Interpretation and Definitions
 
Interpretation
The words of which the initial letter is capitalized have meanings defined under the
following conditions. The following definitions shall have the same meaning regardless
of whether they appear in singular or in plural.
 
Definitions
For the purposes of this Privacy Policy:
 
You means the individual accessing or using the Service, or the company, or other legal
entity on behalf of which such individual is accessing or using the Service, as applicable.
Under GDPR (Genera lData Protection Regulation), You can be referred to as the Data
Subject or as the User as you are the individual using the Service.
​
Company (referred to as either "the Company", "We", "Us"or "Our" in this Agreement)
refers to
miPWR Ltd, Bruntwood Centre City, 7 Hill Street, Birmingham, B5 4UA
​
For the purpose of the GDPR, the Company is the Data Controller.
Application means the software program provided by the Company downloaded by You
on any electronic device, named “CODE 3i”.
Application Store means the digital distribution service operated and developed by Apple
Inc. (Apple App Store) or Google Inc. (Google Play Store) in which the Application has
been downloaded.
Affiliate means an entity that controls, is controlled by or is under common control with a
party, where "control" means ownership of 50% or more of the shares, equity interest or
other securities entitled to vote for election of directors or other managing authority.
Account means a unique account created for You to access our Service or parts of our
Service.
Website refers to mipwr.com, accessible from https://mipwr.com
​
Service refers to the Website or Application
​
Country refers to United Kingdom
 
Service Provider means any natural or legal person who processes the data on behalf
of the Company. It refers to third-party companies or individuals employed by the
Company to facilitate the Service, to provide the Service on behalf of the Company, to
perform services related to the Service or to assist the Company in analysing how the
Service is used. For the purpose of the GDPR, Service Providers are considered Data
Processors.
 
Third-party Social Media Service refers to any website or any social network website
through which a User can log in or create an account to use the Service.
 
Personal Data is any information that relates to an identified or identifiable individual.
For the purposes for GDPR, Personal Data means any information relating to You such
as a name, an identification number, location data, online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic, cultural or
social identity. For the purposes of the CCPA, Personal Data means any information that
identifies, relates to, describes or is capable of being associated with, or could
reasonably be linked, directly or indirectly, with You.
Cookies are small files that are placed on Your computer, mobile device or any other
device by a website, containing the details of Your browsing history on that website
among its many uses.
Device means any device that can access the Service such as a computer, a mobile
phone or a digital tablet.
Usage Data refers to data collected automatically, either generated by the use of the
Service or from the Service infrastructure itself (for example, the duration of a page visit).
Data Controller, for the purposes of the GDPR (General Data Protection Regulation),
refers to the Company as the legal person which alone or jointly with others determines
the purposes and means of the processing of Personal Data.
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities,
in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to
develop and implement a mechanism for allowing internet users to control the tracking of
their online activities across websites.
Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the
Company as the legal entity that collects Consumers' personal information and
determines the purposes and means of the processing of Consumers' personal
information, or on behalf of which such information is collected and that alone, or jointly
with others, determines the purposes and means of the processing of consumers'
personal information, that does business in the State of California.
Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a
natural person who is a California resident. A resident, as defined in the law, includes (1)
every individual who is in the USA for other than a temporary or transitory purpose, and
(2) every individual who is domiciled in the USA who is outside the USA for a temporary
or transitory purpose.
Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling,
renting, releasing, disclosing, disseminating, making available, transferring, or otherwise
communicating orally, in writing, or by electronic or other means, a Consumer's Personal
information to another business or a third party for monetary or other valuable
consideration.
​
Collecting and Using Your Personal Data
 
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. Personally
identifiable information may include, but is not limited to:
• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Usage Data
​
Usage Data
Usage Data is collected automatically when using the Service. Usage Data may include
information such as Your Device's Internet Protocol address (e.g. 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.
When You access the Service by or through a mobile device, We may collect certain
information automatically, including, but not limited to, the type of mobile device You
use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile
operating system, the type of mobile Internet browser You use, unique device identifiers
and other diagnostic data. We may also collect information that Your browser sends
whenever You visit our Service or when You access the Service by or through a mobile
device.
 
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service
and store certain information. Tracking technologies used are beacons, tags, and scripts
to collect and track information and to improve and analyse Our Service. 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 parts of our
Service. Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain
on your personal computer or mobile device when You go offline, while Session Cookies
are deleted as soon as You close your web browser. Learn more about cookies: All
About Cookies. We use both session and persistent Cookies for the purposes set out
below:
• Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available
through the Website and to enable You to use some of its features. They help to
authenticate users and prevent fraudulent use of user accounts. Without these
Cookies, the services that You have asked for cannot be provided, and We only
use these Cookies to provide You with those services.
• Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies Administered by: Us Purpose: These Cookies identify
if users have accepted the use of cookies on the Website.
• Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You
use the Website, such as remembering your login details or language
preference. The purpose of these Cookies is to provide You with a more
personal experience and to avoid You having to re-enter your preferences every
time You use the Website.
• Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the
Website and how users use the Website. The information gathered via these
Cookies may directly or indirectly identify you as an individual visitor. This is
because the information collected is typically linked to a pseudonymous
identifier associated with the device you use to access the Website. We may
also use these Cookies to test new advertisements, pages, features or new
functionality of the Website to see how our users react to them.
For more information about the cookies we use and your choices regarding cookies,
please visit our Cookies Policy or the Cookies section of our Privacy Policy.
 
Use of Your Personal Data
 
The Company may use Personal Data for the following purposes:
• To provide and maintain our Service, including to monitor the usage of our
Service.
• To manage Your Account: to manage Your registration as a user of the Service.
The Personal Data You provide can give You access to different functionalities
of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking
of the purchase contract for the products, items or services You have purchased
or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other
equivalent forms of electronic communication, such as a mobile application's
push notifications regarding updates or informative communications related to
the functionalities, products or contracted services, including the security
updates, when necessary or reasonable for their implementation.
• 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.
• To manage Your requests: To attend and manage Your requests to Us.
We may share your personal information in the following situations:
• With Service Providers: We may share Your personal information with Service
Providers to monitor and analyse the use of our Service, to contact You.
• For Business transfers: We may share or transfer Your personal information in
connection with, or during negotiations of, any merger, sale of Company assets,
financing, or acquisition of all or a portion of our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case
we will require those affiliates to honour this Privacy Policy. Affiliates include Our
parent company and any other subsidiaries, joint venture partners or other
companies that We control or that are under common control with Us.
• With Business partners: We may share Your information with Our business
partners to offer You certain products, services or promotions.
• With other users: when You share personal information or otherwise interact in
the public areas with other users, such information may be viewed by all users
and may be publicly distributed outside. If You interact with other users or
register through a Third-Party Social Media Service, Your contacts on the Third-
Party Social Media Service may see Your name, profile, pictures and description
of Your activity. Similarly, other users will be able to view descriptions of Your
activity, communicate with You and view Your profile.
 
Retention of Your Personal Data
The Company 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 (for example, if we are required to
retain your data to comply with applicable laws), resolve disputes, and enforce our legal
agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is
generally retained for a shorter period of time, 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 Your Personal Data
Your information, including Personal Data, is processed at the Company's operating
offices and in any other places where the parties involved in the processing are located.
It means that this information 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 than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information
represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is
treated securely and in accordance with this Privacy Policy and no transfer of Your
Personal Data will take place to an organization or a country unless there are adequate
controls in place including the security of Your data and other personal information.
 
Disclosure of Your Personal Data
 
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data
may be transferred. We will provide notice before Your Personal Data is transferred and
becomes subject to a different Privacy Policy.
 
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal
Data if required to do so by law or in response to valid requests by public authorities
(e.g. a court or a government agency).
 
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action
is necessary to:
• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability
​
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that 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.
Detailed Information on the Processing of Your Personal Data
Service Providers have access to Your Personal Data only to perform their tasks on Our
behalf and are obligated not to disclose or use it for any other purpose.
​​
Google Calendar Integration

CODE 3i offers an optional feature that lets you connect your Google Calendar. If you choose to connect it, CODE 3i requests read-only access to the events on your primary Google Calendar (https://www.googleapis.com/auth/calendar.events.readonly) and your basic Google profile (your email address, via the openid and email scopes).

What we access and why. We read events on your own primary calendar for a rolling 7-day window, solely to (a) show you your upcoming meetings inside CODE 3i and (b) detect when a meeting has ended so we can prompt you to complete a meeting "decoder" reflection. For those events we read the start and end times, the title, the location, the names and email addresses of attendees, the organiser, and any video-conferencing link. We never read the description or body text of your events. We access only your own primary calendar — never any other calendar, never other users' calendars, and never organisation-wide data. We make no changes to your calendar: we never create, edit or delete events.

What we store. We store the OAuth access and refresh tokens needed to make these requests, encrypted at rest (AES-256-GCM). We do not keep a copy of your calendar. However, if you choose to create a decoder from one of your meetings, the details of the meeting you selected — its title, date, location, and the names and email addresses of the attendees — are saved as part of that decoder record, so that the request can be sent and the responses attributed to the right meeting.

AI features. CODE 3i includes an AI assistant powered by Anthropic's Claude. The data sent to Anthropic is limited to what you type into the assistant, your CODE profile results, and knowledge-base material published by your organisation. Google Workspace data — including your calendar events, their attendees and any meeting details — is never transmitted to Anthropic or to any other AI or machine-learning service. We access Claude through Anthropic's commercial API under their Commercial Terms of Service, under which customer inputs and outputs are not used to train Anthropic's models. We use no other AI or machine-learning provider.

We never sell this data or use it for advertising. Notwithstanding any other statement in this policy, data obtained through Google APIs is never sold, shared with advertising partners, or used for advertising or any purpose other than providing and improving the features described above.

How to disconnect. You can revoke CODE 3i's access at any time by clicking "Disconnect" on the Calendar Integrations page in CODE 3i (which deletes the stored tokens), or via your Google Account at https://myaccount.google.com/permissions.

Limited Use. CODE 3i's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements.

​Sub-processors

Pantheon Systems, Inc. — hosting for the CODE 3i platform
Adaptive Web Ltd — platform engineering and support, under contract to MIPWR Ltd
PostHog, Inc. — product analytics (EU Cloud)
Functional Software, Inc. (Sentry) — error monitoring (Germany)

Analytics
We use PostHog (PostHog, Inc., EU Cloud, hosted in the European Union) to understand how the CODE 3i app is used. PostHog records which pages of the app are visited and when, the product area, and sign-in events. These are linked to an internal account identifier and your organisation, not to your name or email address. PostHog is configured without cookies, and we do not use it to record what you type, your screen, or the content of your assessments or reports. We process this data on the basis of our legitimate interest in improving the Service. Analytics data is retained for 12 months.
​
Error Monitoring
We use Sentry (Functional Software, Inc., data region: Germany) to detect and diagnose errors in the CODE 3i app. When an error occurs, Sentry receives technical diagnostics — the page, browser type, the error message and a trace of recent API requests — together with an internal account identifier so we can reproduce the problem. We process this data on the basis of our legitimate interest in keeping the Service reliable and secure. Error data is retained for 90 days.

GDPR Privacy
Service Providers have access to Your Personal Data only to perform their tasks on Our
behalf and are obligated not to disclose or use it for any other purpose.
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
• Consent: You have given Your consent for processing Personal Data for one or
more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the
performance of an agreement with You and/or for any pre-contractual
obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a
legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your
vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out
in the public interest or in the exercise of official authority vested in the
Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of
the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to
the processing, and in particular whether the provision of Personal Data is a statutory or
contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to
guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:
• Request access to Your Personal Data. The right to access, update or delete the
information We have on You. Whenever made possible, you can access, update
or request deletion of Your Personal Data directly within Your account settings
section. If you are unable to perform these actions yourself, please contact Us to
assist You. This also enables You to receive a copy of the Personal Data We
hold about You.
• Request correction of the Personal Data that We hold about You. You have the
right to to have any incomplete or inaccurate information We hold about You
corrected.
• Object to processing of Your Personal Data. This right exists where We are
relying on a legitimate interest as the legal basis for Our processing and there is
something about Your particular situation, which makes You want to object to
our processing of Your Personal Data on this ground. You also have the right to
object where We are processing Your Personal Data for direct marketing
purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or
remove Personal Data when there is no good reason for Us to continue
processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a thirdparty
You have chosen, Your Personal Data in a structured, commonly used,
machine-readable format. Please 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 Your consent. You have the right to withdraw Your consent on using
your Personal Data. If You withdraw Your consent, We may not be able to
provide You with access to certain specific functionalities of the Service.
Your Rights under the GDPR
You may exercise Your rights of access, rectification, cancellation and opposition by
contacting Us. Please note that we may ask You to verify Your identity before
responding to such requests. If You make a request, We will try our best to respond to
You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and
use of Your Personal Data. For more information, if You are in the European Economic
Area (EEA), please contact Your local data protection authority in the EEA.
You have the right under this Privacy Policy, and by law if You are within the EU, to:
 
CCPA Privacy
Your Rights under the CCPA
Under this Privacy Policy, and by law if You are a resident of California, You have the
following rights:
• The right to notice. You must be properly notified which categories of Personal
Data are being collected and the purposes for which the Personal Data is being
used.
• The right to access / the right to request. The CCPA permits You to request and
obtain from the Company information regarding the disclosure of Your Personal
Data that has been collected in the past 12 months by the Company or its
subsidiaries to a third-party for the third party's direct marketing purposes.
• The right to say no to the sale of Personal Data. You also have the right to ask
the Company not to sell Your Personal Data to third parties. You can submit
such a request by visiting our "Do Not Sell My Personal Information" section or
web page.
• The right to know about Your Personal Data. You have the right to request and
obtain from the Company information regarding the disclosure of the following:
- The categories of Personal Data collected
- The sources from which the Personal Data was collected
- The business or commercial purpose for collecting or selling the Personal Data
- Categories of third parties with whom We share Personal Data
- The specific pieces of - Personal Data we collected about You
• The right to delete Personal Data. You also have the right to request the deletion
of Your Personal Data that have been collected in the past 12 months.
• The right not to be discriminated against. You have the right not to be
discriminated against for exercising any of Your Consumer's rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of
discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services
or a different level or quality of goods or services.
​
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if you are a California
resident, You can email or call us or visit our "Do Not Sell My Personal Information"
section or web page.
The Company will disclose and deliver the required information free of charge within 45
days of receiving Your verifiable request. The time period to provide the required
information may be extended once by an additional 45 days when reasonable necessary
and with prior notice.
 
Do Not Sell My Personal Information
We do not sell Your personal information. We do not share Your personal information with advertising partners, and we do not use it for interest-based or personalized advertising.
Please note that any opt out is specific to the browser You use. You may need to opt out
on every browser that you use.
Because we do not sell Your personal information or use it for personalised advertising, no opt-out is necessary.
You can still manage non-essential cookies at any time using the cookie consent controls on the site.
 
Mobile Devices
Your mobile device may give you the ability to opt out of the use of information about the
apps you use in order to serve you ads that are targeted to your interests:
• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android
devices
• "Limit Ad Tracking" on iOS devices*
You can also stop the collection of location information from Your mobile device by
changing the preferences on your mobile device.
"Do Not Track" Policy as Required by California Online Privacy Protection Act
(CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities. If You are
visiting such websites, You can set Your preferences in Your web browser to inform
websites that You do not want to be tracked. You can enable or disable DNT by visiting
the preferences or settings page of Your web browser.
Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light law), California
residents with an established business relationship with us can request information once
a year about sharing their Personal Data with third parties for the third parties' direct
marketing purposes.
If you'd like to request more information under the California Shine the Light law, and if
you are a California resident, You can contact Us using the contact information provided
below.
California Privacy Rights for Minor Users (California Business and Professions Code
Section 22581)
California Business and Professions Code section 22581 allow California residents
under the age of 18 who are registered users of online sites, services or applications to
request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, You can contact
Us using the contact information provided below, and include the email address
associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of
content or information posted online and that the law may not permit or require removal
in certain circumstances.
 
Links to other websites
Our Service may contain links to other websites that are not operated by Us. If You click
on 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.
 
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.
We will let You know via email and/or a prominent notice on Our Service, prior to the
change becoming effective and update the "Last updated" date at the top of this Privacy
Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to
this Privacy Policy are effective when they are posted on this page.
​
Contact us
If you have any questions about this Privacy Policy, You can contact us:
By email: support_team@mipwr.com