Privacy Notice

1. Overview of the Binome General Privacy Policy

We at Binome understand that privacy and data protection are important to our customers. We have produced this Binome General Privacy Policy with the aim of giving our customers the information they need to provide certainty and accountability regarding our treatment of personal data.

This Binome General Privacy Policy explains how we use your personal data: how we collect, hold, and process it. It also provides an explanation of the legal rights data subjects have to their personal data.

In the event such policies are applicable, this Binome General Privacy Policy is to be read as incorporating and supplemented by: the Binome Cookies Policy; in the event the customer is a user of Mira's beta, the Mira Individual Plan Privacy Policy Addendum; in the event the customer is a recipient of Binome's software engineering services, any data agreement with Binome which identifies itself as being incorporated into and supplementing this Binome General Privacy Policy.

2. Contact Us

Our company name is Binome Technologies Ltd, a private limited company registered in England under the company number 15789998.

Our registered address is: 196e Campden Hill Road, London, United Kingdom, W8 7TH.

To reach our Data Protection Office or raise any data protection queries, contact the email address: privacy@binome.dev. A Data Protection Officer has not formally been appointed.

3. Data Subject Rights

Under the Data Protection Legislation data subjects have the following rights: (a) the right to be informed about our collection and use of your personal data; (b) the right to access the personal data we hold about you; (c) the right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete; (d) the right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold; (e) the right to restrict (i.e. prevent) the processing of your personal data; (f) the right to object to us using your personal data for a particular purpose or purposes; (g) the right to withdraw consent — if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time; (h) the right to data portability — if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases; and (i) rights relating to automated decision-making and profiling — Mira generates AI outputs in response to your inputs, which do not in themselves constitute solely automated decisions producing legal or similarly significant effects within the meaning of Article 22 UK GDPR. You should not rely on Mira outputs for legally significant decisions about yourself or others without human review.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 2.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 2.

If a customer wants to know what personal data we have about them, they can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a subject access request. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 2. There is not normally any charge for a subject access request. If your request is manifestly unfounded or excessive (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

4. Personal Data We Collect

We may collect and hold some or all of the personal and non-personal data set out below. We do not collect special category or sensitive personal data, personal data relating to children, or data relating to criminal convictions and/or offences. Although safeguards such as automatic detection have been implemented there is never total prevention of such collection; in the event you believe such data has been collected by Mira please inform us immediately so that we may take reasonable measures.

Identity and contact information including names, email addresses, phone numbers: this data is requested from and provided by users on sign-up, and/or further data of this category may be uploaded by users at the user's own risk themselves into the Mira software.

Payment information including card details, bank account numbers, and billing details including account name and billing address: this data is requested from and provided by users who register for a subscription plan for a paid version of Mira, and/or further data of this category may be uploaded by users at the user's own risk themselves into the Mira software.

Communication information, including emails and calls made to our customer services and sales teams: data of this category will be automatically recorded by us upon its creation.

Profile information including preferences, and purchase and subscription history: data of this category will be automatically recorded by us upon its creation.

Data from third parties including contact and profile information: data of this category may be obtained from third parties via commercial agreements.

Log and troubleshooting information, including log information regarding how the Mira software is used: data of this category will be automatically recorded by us should a Mira customer elect to submit a ticket and share this information with us.

Feedback on our services and use of the Mira software: data of this category will be recorded when users provide responses to our surveys and questionnaires, or any other input request.

The individuals from which we may gather and use data can include: you directly; business contacts; third parties connected to your customers; and any other people that the organisation has a relationship with or may need to contact.

5. How and Why We Use Your Personal Data

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following describes how we may use your personal data and our lawful bases for doing so.

Identity and contact information is used for: administering our contractual relationship and maintaining accounts and profiles of our users (lawful basis: contract performance; and legitimate interests — necessary to ensure the meeting of legal obligations such as tax records and statutory record-keeping, and service optimisation for the user); personalising and tailoring our products and/or services for you (lawful basis: legitimate interests — by tailoring our Mira software, we ensure that the processing we perform is restrained to that which is perceived to be most relevant and beneficial for the user); and supplying you with information that you have opted in to (lawful basis: consent — we contact you only where you have actively opted-in to receive such information, and you may withdraw this consent at any time).

Payment information is used for managing payments for our products and/or services (lawful basis: contract — this information is necessary for us to administer paid subscriptions, manage billing, and perform our obligations under the contract).

Communication information is used for communicating with you (lawful basis: legitimate interests — we have a legitimate interest in communicating with users to provide support, respond to queries, and manage ongoing service provision).

Profile information is used to ensure we understand what our customers want from us and what they pay for (lawful basis: legitimate interests — we use this information to understand account activity, maintain service quality, and personalise communication where appropriate).

Data from third parties is used for marketing to potential new customers and building our customer profiles (lawful basis: legitimate interests — where permitted, we use third-party-provided contact or profile information to keep user records accurate and to support service delivery).

Log and troubleshooting information is used for improving our services and abuse detection (lawful basis: legitimate interests — this data enables us to investigate issues, ensure system functionality, and maintain a high-quality software product for our users).

Feedback on our services and use of the Mira software is used for improving Mira (lawful basis: legitimate interests — user feedback helps us improve our products, develop new features, and enhance the overall user experience).

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 2.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

6. When We May Disclose Your Personal Data

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may sometimes contract with the following third parties to supply products and/or services: Google Cloud EMEA Limited (Ireland), providing cloud storage and database services, located in the United Kingdom; Notion, providing online database and organisational tools through which we may organise and keep customer profiles and details, located in the United States (assessed as providing adequate protection under Adequacy Regulations or UK data bridge); and PostHog, providing analytics collection and processing, located in Germany.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party's obligations under the law, as described in Part 7.

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained in Part 7.

7. Data Storage

We will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

We will store some of your personal data within the European Economic Area (the EEA). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.

We may also store some or all of your personal data in countries outside of the UK, known as third countries. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation. We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner's Office.

The security of your personal data is essential to us. To protect your data, we take a number of important measures, including: limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner's Office where we are legally required to do so.

8. Data Retention

We retain personal data only as long as necessary for the purposes set out in this notice or as required by law. Retention periods are as follows.

Identity and contact information: for the duration of the user's account and use of the product, and to be held for another 2 years after account closure (to handle disputes, audit queries, service history).

Payment information: to be held for up to 6 years from the end of the financial year in which the user's transaction occurred.

Business information including information concerning revenue and customers: as long as necessary for the contract, plus up to 6 years after contract end, to comply with standard commercial record-keeping and limitation periods for legal claims.

Communication information: to be held for up to 2-3 years after resolution of an enquiry or closure of the account and ending of the user's use of the software, depending on support requirements and audit needs, ensuring data is not retained longer than required.

Profile information: to be held for the duration of the user's account and software usage and 2 years following termination or usage and account closure.

Data from third parties: to be held for 1 year from receipt if no active relationship develops; or, in the event a relationship develops, for the duration of the user's account and software usage and 2 years following termination or usage and account closure.

Log and troubleshooting information: to be held for 1 year.

Feedback on our services and use of the Mira software: to be held for 2 years following collection.

9. Data Security

Binome has adopted strong internal safeguards and taken organisational measures designed to protect the personal data we hold. Due to the fact that no internet information system is ever completely secure, we encourage customers to make careful determinations on what information they choose to share with us.

10. Children

Binome offers no services to individuals under 18 years of age, and intends that no customer accounts are shared with under 18s. We do not intentionally request this information. Contact us at the details provided in Part 2 should you believe an underaged individual has accessed and provided personal data to us — we shall investigate and take appropriate measures accordingly.

11. Updates to the Binome General Privacy Policy

We may change this Binome General Privacy Policy from time to time, including to its addendums. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

We will notify customers of any changes to this Binome General Privacy Policy to their registered email, and also detail any such updates on our website, binome.dev.

This Binome General Privacy Policy is deemed authorised and effective from 22/05/2026, and shall be due for review by 22/05/2027.

12. Interpretation

This Binome General Privacy Policy shall be governed by, and construed in accordance with, the data protection laws of England and Wales.

All references to Data Protection Legislation means all applicable legislation in force from time to time in the United Kingdom applicable to data protection and privacy including, but not limited to, the UK GDPR, the Data Protection Act 2018 (and regulations made thereunder), and the Privacy and Electronic Communications Regulations 2003 as amended. Terms used in this Binome General Privacy Policy which hold meanings under the Data Protection Legislation shall hold those meanings herein.

Any dispute, controversy, proceedings or claim between the Parties relating to this Agreement (including any non-contractual matters and obligations arising therefrom or associated therewith) shall fall within the jurisdiction of the courts of England and Wales.

13. Credit

This policy was created with adaptation of the document template BS.DAT.PRIV.07 Privacy Notice provided by and Copyright of Simply-Docs (www.simply-docs.co.uk).

© Binome Technologies Ltd. Company number 15789998.