1. Controller / contact details
This policy describes general data protection principles applicable to the Miridian website. The legal identity, registered address and contact details of the entity responsible for processing personal data must be confirmed before publication.
For information about data protection rights, please use the verified contact details published in Miridian's legal notice.
2. General information on the processing of personal data
2.1. General information
Personal data is information relating to an identified or identifiable individual. Depending on the services provided, this may include identification details, contact information, information submitted through forms, technical access data and account-related information.
Only data necessary for specified and lawful purposes should be collected. Certain services may require information to comply with contractual or legal obligations.
2.2. Purposes and legal basis
Under Article 6 of the General Data Protection Regulation (GDPR), processing must be supported by an appropriate legal basis.
2.2.1 Consent pursuant to Art. 6 (1) (a) GDPR
Where processing relies on consent, the individual may withdraw consent at any time for future processing. Withdrawal does not affect the lawfulness of processing before withdrawal.
2.2.2 Fulfilment of contractual obligations pursuant to Art. 6 (1) (b) GDPR
Personal information may be processed when necessary to take steps before entering into a contract or to perform a contract with an individual.
2.2.3 Compliance with legal requirements pursuant to Art. 6 (1) (c) GDPR
Processing may be required to comply with applicable legal obligations. Any obligations specific to a regulated financial institution must be identified based on the actual status and activities of the controller.
2.2.4 Legitimate interests pursuant to Art. 6 (1) (f) GDPR
Where appropriate, processing may be based on legitimate interests, subject to the rights and freedoms of the individual. Examples include:
- Ensuring website and IT security.
- Preventing and investigating misuse or fraud.
- Handling enquiries and improving website performance.
- Establishing, exercising or defending legal claims.
2.3 Processing of personal data of third parties
Information concerning representatives, contacts and other individuals may be processed where necessary and lawful. The applicable purpose and legal basis depend on the specific circumstances.
3. Processing of your personal data when accessing our website and apps
3.1. Hosting
Websites commonly rely on hosting and infrastructure providers. For reference, Amazon Web Services publishes information about its data protection practices. This link does not mean that Miridian uses AWS. Any actual hosting provider and relevant processing arrangements must be disclosed once confirmed.
Information on European Union standard contractual clauses is available from EUR-Lex (Commission Implementing Decision EU 2021/914).
3.2. Use of our website for information purposes
Technical access data may be processed when a visitor requests a page, for example:
- IP address of the requesting device
- Type, language and version of web browser
- Operating system and its version
- Date and time of the visit
- Requested page and response status
- Referrer and technical error information
Actual log collection and retention periods must reflect the site's implemented hosting and security systems.
3.3. Use of cookies, tracking tools and third-party services
3.3.1 General information
Cookies and similar technologies can enable core functionality, remember preferences and support optional analytics or advertising. Where legally required, non-essential technologies must not be activated without consent. See the Cookie Policy for website-specific details when available.
3.3.2 Authentication services
Authentication technologies may help protect access to user accounts. Examples of providers in this field include Auth0 and Futurae. Their inclusion here is informational, not a statement of use by Miridian.
3.3.3 Consent management
Consent management tools can record user choices about optional technologies. For general information, see Usercentrics Privacy Policy. The actual consent management service, if any, should be named in the final policy.
3.3.4 Performance monitoring and cybersecurity
Performance and security monitoring tools can help detect technical errors and suspicious activity. An example is Datadog. No particular provider or data retention period is asserted here.
3.3.5 Protection against automated access
Bot-protection services may help prevent spam and automated abuse. See Friendly Captcha's privacy information as a reference.
3.3.6 Analytics and marketing technologies
Where analytics or marketing services are enabled, their use, the data involved and applicable consent choices must be described specifically. The following external privacy resources are provided for reference:
- Google Privacy Policy — including Google Analytics, Google Ads and YouTube.
- Meta Privacy Policy.
- LinkedIn Privacy Policy.
- Microsoft Privacy Statement.
- TikTok Privacy Policy.
- Reddit Privacy Policy.
- Adjust Privacy Policy.
These are third-party reference links. They do not establish that Miridian uses any of the listed technologies.
4. Provision of services
4.1. Registration and account information
If registration or account services are offered, relevant personal information may include name, contact details, authentication information and details needed to provide the selected service. The specific data categories and legal bases must be confirmed for each actual service.
4.2. Identity verification
Identity verification may be required for certain financial services. External identification providers include POSTIDENT and Fourthline. These references do not imply a contractual relationship with Miridian.
4.3. Financial transactions
Where transactions are available, personal data may need to be processed to fulfil instructions, maintain records and comply with applicable law. Actual service providers and recipients must be specified.
4.4. Communications
Contact requests may require processing of names, email addresses, message content and associated technical information to respond to enquiries.
4.5. Retention periods
Information should be retained only for as long as necessary for the relevant purpose, subject to applicable legal requirements. Exact retention periods must be based on Miridian's actual processing activities.
5. Recipients and third-party processors
Personal information may be shared with authorised processors, professional advisers or competent authorities where lawful and necessary. Any actual recipients, processor categories and contractual arrangements must be identified in the final published policy.
External privacy policies are linked above to help readers learn about the practices of those providers independently; listing them does not establish a business relationship.
6. International transfers of personal data
If personal data is transferred outside the European Economic Area, an appropriate legal transfer mechanism may be required. Information on international data protection arrangements is available from the European Commission.
7. Your rights as a data subject
Depending on applicable law and the circumstances, individuals may have the right to access, correct or erase their personal data, restrict processing, request portability, object to certain processing and withdraw consent where processing relies on consent.
Information about these rights is available from the European Commission. Individuals may also have the right to lodge a complaint with a competent supervisory authority.
8. Data security
Appropriate technical and organisational measures should protect personal information against unauthorised access, loss, alteration and unlawful disclosure. The final policy should accurately describe the security practices relevant to the actual services.
9. Changes to this privacy policy
This policy may be updated to reflect changes in website features, processing activities or applicable law. The publication date and any material changes should be indicated in the final version.
10. Further information and contact
For privacy enquiries, use the verified contact information in the Miridian legal notice.