Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, and how and why we collect, store, use, and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).
1. Key Terms
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Net Zero Projects Limited, trading as minimass |
| Personal data | Any information relating to an identified or identifiable individual |
| Special category personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membershipGenetic dataBiometric data concerning health, sex life or sexual orientation |
| Data subject | The individual who the personal data relates to |
2. Personal Data We Collect About You
The personal data we collect about you depends on the particular products and services we provide to you. We will collect and use the following personal data about you:
· Your name and contact information, including email address and telephone number and company details
· Approximate location data, if you choose to give this to us
· Your billing and transaction information
· Your professional online presence, e.g., LinkedIn profile
· Your contact history
· Information from accounts you link to us, e.g., Facebook
· Your responses to surveys
3. How and why we use your personal data
We collect and use this personal data for the purposes described in the section.
3.1 How Your Personal Data is Collected
We collect most of this personal data directly from you—in person, by telephone, text, or email and/or via our website. However, we may also collect information:
· From publicly accessible sources, e.g., Companies House;
· From cookies on our website—for more information on our use of cookies, please see our cookie policy minimass.net/cookie-policy/
3.2 How and Why We Use Your Personal Data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.,:
· Where you have given consent
· To comply with our legal and regulatory obligations;
· For the performance of a contract with you or to take steps at your request before entering into a contract; or
· For our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use (process) your personal data for why:
| What we use your personal data for | Our reasons |
| To provide products and services to you | To perform our contract with you or to take steps at your request before entering into a contract |
| To prevent and detect fraud against you or Net Zero Projects Limited | For our legitimate interests, i.e., to minimise fraud that could be damaging for you and/or us |
| Screening for financial and other sanctions or embargoes Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety law or rules issued by our professional regulator | Depending on the circumstances: • To comply with our legal and regulatory obligations • In other cases, for our legitimate interests, i.e., to protect our business, interests and rights |
| To enforce legal right or defend or undertake legal proceedings | Depending on the circumstances: • To comply with our legal and regulatory obligations • In other cases, for our legitimate interests, i.e., to protect our business, interests and rights |
| Ensuring business policies are adhered to, e.g., policies covering security and internet use | For our legitimate interests, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information | Depending on the circumstances: • For our legitimate interests, i.e., to protect trade secrets and other commercially valuable information • To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, e.g., in relation to understanding its customer base and the development and improvement to the minimass website. | For our legitimate interests, i.e., to improve our commercial offering With your consent in relation to our use of Google Analytics |
| Preventing unauthorised access and modifications to systems | Depending on the circumstances: • For our legitimate interests, i.e., to protect, prevent, and detect criminal activity that could be damaging to you and/or us • To comply with our legal and regulatory obligations |
| Protecting the security of systems and data used to provide the goods and services | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Updating and enhancing customer records | Depending on the circumstances: • To perform our contract with you or to take steps at your request before entering into a contract • To comply with our legal and regulatory obligations • For our legitimate interests, e.g., making sure that we can keep in touch with our customers about existing orders and new products |
| Ensuring safe working practices, staff administration and assessments | Depending on the circumstances: • To comply with our legal and regulatory obligations • For our legitimate interests, e.g., to make sure we are following our own internal procedures and working efficiently |
| Marketing our products and services to: • Existing customers • Third parties who have previously expressed an interest in our services • Third parties with whom we have had no previous dealings | For our legitimate interests, i.e., to promote our business to existing customers and parties who have previously expressed an interested in our products and/or services With your consent in relation to third parties with whom we have had no previous dealings |
| External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts | Depending on the circumstances: • For our legitimate interests, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards • To comply with our legal and regulatory obligations |
| To share your personal data with third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances: • To comply with our legal and regulatory obligations • In other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
| Email tracking | If you subscribe to receive our Newsletter, your response to emails you receive may be logged, allowing us to determine, for example, if email is opened and if links within the email have been visited. This information is used to assess the effectiveness of such email communications so that they can be improved and may occasionally be used to send relevant further communications in response to your actions (e.g. clicking a particular link) or inactions (e.g. not opening an email), in accordance with your contact preferences. You can unsubscribe from recurring email communications at any time using the unsubscribe link contained in each email communications, or by updating your contact preferences (by contacting us at infor@minimass.net). |
3.3 How and Why We Use your Personal Data—More Detail
More details about how we use your personal data and why are set out in the table below.
| Purpose | Processing operation | Lawful basis relied on under the UK GDPR and EU GDPR | Relevant categories of personal data |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | Addressing and sending communications to you as required by data protection laws, i.e.,: • The UK GDPR or Data Protection Act 2018 • The EU GDPR | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) | • Your name, address and contact information, including email address and telephone number and company details |
| Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices | Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you | • Your name, address and contact information, including email address and telephone number and company details | |
| Email tracking for email marketing communications (e.g. our Newsletter) | Assessing the effectiveness of email marketing communications | Your consent (Article 6(1)(a) | • Your name and email address, email marketing communication email open, and click-through information |
3.4 How and Why We Use Your Personal Data—Special Category Personal Data
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g.:
· We have your explicit consent
· The processing is necessary to protect your (or someone else's) vital interests where you are physically or legally incapable of giving consent —or—
· The processing is necessary to establish, exercise, or defend legal claims
3.5 How and Why We Use Your Personal Data—Sharing
See "Who We Share Your Personal Data With" for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, text message, telephone, or post) about our products and services, including newsletters, event invitations, and the launch of new products and services.
We have a legitimate interest in using your personal data as an existing customer or party who has previously expressed an interest in our business for marketing purposes (see above “How and Why We Use Your Personal Data”). This means we do not usually need your consent to send you marketing information. For this same purpose, we rely on the consent of third parties with whom we have had no previous dealings.
You have the right to opt out of or remove your consent to receiving marketing communications at any time by:
· Contacting us at info@minimass.net
· Using the unsubscribe link in emails
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell it to or share it with other organisations for marketing purposes.
3.6 Who We Share Your Personal Data With
We routinely share personal data with:
· Third parties we use to help us run our business, e.g., marketing agencies or website hosts;
· Our bank;
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
· Our and their external auditors, e.g., in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
· Our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
· Law enforcement agencies, courts, tribunals, and regulatory bodies to comply with our legal and regulatory obligations
· Other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
3.7 Your Personal Data With Google for Google Analytics
More details about who we share your personal data with and why are set out in the table below.
| Recipient | Processing operation (use) by recipient | Relevant categories of personal data transferred to recipient |
| Analysis of Google Analytics data, e.g. to improve Google search results, better understand online behaviour and trends, improvement of Google products and services | Sessions statistics (page use, page interactions and paths through to website) |
3.8 Who We Share Your Personal Data With—Further Information
If you would like more information about who we share our data with and why, please contact us (see "How to contact us" below).
4. Where Is Your Personal Data Held
Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: "Who We Share Your Personal Data With").
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: "Transferring Your Personal Data Out of the UK/EEA".
5. How Long Your Personal Data Will Be Kept
We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, If you decide to no longer receive marketing material from us, we will remove your name from our marketing list.
Different retention periods apply for different types of personal data. For further details please contact us (see "How to contact us" below).
6. Transferring Your Personal Data Out of the UK and EEA
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
We will transfer your personal data to our service providers located outside the UK.
As we are based in the UK we will also transfer your personal data from the EEA to the UK.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
· In the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an "adequacy regulation") further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available. We rely on adequacy regulations for transfers to the following countries: USA
· In the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an "adequacy decision") further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available. We rely on adequacy decisions for transfers to the following countries: USA
· There are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
· A specific exception applies under relevant data protection law
Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) we rely on appropriate safeguards such as standard contractual clauses. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) in reliance on standard contractual clauses. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the
6.1 Transferring Your Personal Data Out of the UK and EEA—Further Information
If you would like further information about data transferred outside the UK/EEA, please contact us (see "How to Contact Us" below).
7. Your Rights
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data—in certain circumstances, e.g., if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object | The right to object: • at any time to your personal data being processed for direct marketing (including profiling) where we have relied on our legitimate interests as the lawful basis for processing • in certain other situations to our continued processing of your personal data, e.g., processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
| Not to be subject to automated individual decision-making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
| Right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by emailing info@minimass.net with the subject line "Data subject rights" Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For more information on each of those rights, including the circumstances in which they apply, please contact us (see "How to Contact Us" below) or see the Guidance from the UK Information Commissioner's Office (ICO) on individuals rights.
If you would like to exercise any of those rights, please:
· Email or write to us—see below: "How to contact us";
· Provide enough information to identify yourself (e.g,, including your full name and contact details) and any additional identity information we may reasonably request from you; and
· Let us know what right you want to exercise and the information to which your request relates
8. Keeping Your Personal Data Secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
9. How to Complain
Please contact us if you have any queries or concerns about our use of your personal data (see below "How to Contact Us"). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with The Information Commissioner in the UK. The UK's Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
10. Changes to This Privacy Policy
This privacy notice was published on July 26, 2024.
We may change this privacy notice from time to time – when we do we will inform you via the website.
11. How to Contact Us
11.1 Individuals in the UK
You can contact us by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Net Zero Project Limited
Mercury House
19-21 Chapel Street
Marlow
Buckinghamshire
England SL7 3HN
info@minimass.net
11.2 Individuals in the EEA
Individuals within the EEA can contact us directly (see above).