Privacy Policy

This Privacy Policy pertains to DealDep Corp., a Delaware corporation (hereinafter: “Miranna”, “We” (or “we”) or “Us” (or “us”) that operates the Miranna website (located at miranna.com; hereafter: “Site” or “Website”) and the Miranna application (hereafter: “App” or, “Application”). As used herein, “Services” means the Site, Application and any other service offered by Miranna.

By continuing to use our Site or App, you accept the terms outlined in this Privacy Policy.

DEFINITIONS

"Personal Information" or "Personal data" is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Process" or "Processing" means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

"Usage Data” is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

CONSENT

By using the Services, or registration with our Site or App, you signify your agreement to the terms and conditions of this Policy and to our collection, use and disclosure of your personal data as set out herein. By giving your consent to us, you retain the right to have your personal data rectified, to be forgotten and/or to be erased.

You may change or withdraw your consent to the collection, use or disclosure of your personal data at any time by contacting us via email at info@miranna.com. In some circumstances, a change or withdrawal of consent may affect your ability to use the Services.

You also agree and accept that we may contact you by email or SMS in relation to your subscription or use of the Site or App. 

1. Introduction

The Miranna allows Learners/Mentees/Clients to connect with Mentors so that Learners who are interested in developing their career or gaining new skills, or personal growth can receive, and the Mentors and Coaches can provide coaching, professional guidance and support. Learners/Mentees/Clients will be able to request to connect with Mentors and Coaches via the Miranna and/or schedule an online meeting to obtain advice and guidance from the Mentor for the purpose of progressing the Learner’s goals (a “Mentorship/Coaching Session”), or get a texting support through messages inside the App.

This Privacy Policy applies to you when you are using Miranna and/or Miranna Services as a mentor or coach (the “Mentor” the “Coach”), and specific provisions which apply when you are using the Miranna Platform and/or the Miranna Services as a learner (the “Mentee” or “Learner” or “Client”). 

Throughout this Privacy Policy, the terms “you” and “your” will refer to Mentors, Coaches, Learners, Clients or Visitors, depending on the context, as defined below.

Mentor: You are using Miranna to provide Mentorship Sessions to Mentees.

Coach: You are using Miranna to provide Coaching Sessions to Mentees.

Mentee/Learner: You are using Miranna to receive Mentorship Sessions from Mentors. 

Visitor: You are exploring our Site or App or using the Miranna.

These categories are not mutually exclusive. For instance, a person registered as a Mentor/Coach may also ask questions to other Mentors/Coaches, becoming a Mentee/Client/Leaner for that specific exchange. Moreover, all Mentees, Clients and Mentors and Coaches are also Visitors, and the provisions for Visitors apply to all Mentees, Clients and Mentors, Coaches as well.

If you are a Mentee or Client and disclose additional Personal Data to a Mentor or a Coach during a Mentorship/Coaching Session, this Privacy Policy does not cover the Mentor’s (or Coach's) practices beyond what is explicitly stated here. Mentors/Coaches are contractually obligated to only contact Clients, Coaches, Mentees through Miranna and to maintain the confidentiality of Mentorship or Coaching Sessions.

2. Personal Data We Collect

For Mentees:

Information You Provide:

You may submit Personal Data to us by creating an account on Miranna, filling out forms or surveys on our Sites or App, or by reaching out to us via phone or email for inquiries or customer support.

The types of information we collect include:

• Contact Details: Such as your name, email address, and phone number.
• Account Information: Including your username and password.
• Media Content: Such as video messages, headshots, and other profile images
• Mentorship or Coaching Sessions Content: Such as audio, text, electronic, visual, or similar information, exchanged on Miranna in course of Mentorship/Coaching Sessions.
• Payment Information: Such as your credit card details for managing paid accounts.
• Subscription type and status (Premium Forever, Yearly, or Monthly), subscription purchase and renewal dates
• Premium Content transaction history, access logs and usage data

For Mentors and Coaches:

Information You Provide:

You may submit Personal Data to us by creating an account on Miranna, filling out forms or surveys on our Sites or App, or by reaching out to us via phone or email for inquiries or customer support.

The types of information we collect include:

• Contact Details: Such as your name, address, email address, and phone number.
• Account Information: Including your username and password.
• Media Content: Such as video messages, headshots, and other profile images
• Mentorship and Coaching Sessions Content: Such as audio, text, electronic, visual, or similar information, exchanged on Miranna in course of Mentorship and Coaching Sessions.
• Professional Details: Such as your resume or CV and other information necessary to verify your qualifications.
• Payment Information: Such as bank account details for payment purposes.

For Visitors:

‍Information we collect:

You may submit Personal Data to us by filling out forms or surveys on our Site or App, or by reaching out to us via email or support chat for inquiries or customer support.

Information from Third Parties:

If you access our Sites or App through third-party services (e.g., Facebook or Google, LinkedIn) or share content from our Sites (or App) on social media, these third-party services may provide us with information about you, depending on their policies and your privacy settings with those services.

Automatically Collected Information:

Like many websites, we collect data sent by your browser when you visit our Sites. This includes:

• Log Data: Such as your browser type and version,  IP address, date and time of your visit, pages visited on our Sites and App, time spent on those pages, and referral sources (e.g., social media or email campaigns).
• Technologies Used: Including cookies, web beacons, clear GIFs, canvas fingerprinting, and other similar technologies, such as Facebook Pixel.
• You can manage cookies through your browser settings.

3. Use of Your Personal Data 

Miranna uses the collected data for various purposes:

• to provide and maintain our Service;
• to notify you about changes to our Service; 
• to allow you to participate in interactive features of our Service when you choose to do so; 
• to provide customer support; 
• to gather analysis or valuable information so that we can improve our Service; 
• to monitor the usage of our Service;
• to detect, prevent and address technical issues;
• to fulfill any other purpose for which you provide it; 
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
• 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;
• in any other way we may describe when you provide the information;
• for any other purpose with your consent;
• to process Premium Subscription purchases, renewals, and cancellations
• to enforce subscription terms and detect refund abuse
• to provide access to Premium Content based on subscription status
• to send notifications about subscription renewals, expirations, and billing issues.

4. Legal Basis For Processing

Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from You only where we have Your consent to do so, where we need the Personal Data to perform a contract with You, or where the processing is in Our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the Personal Data in question.

If we ask You to provide Personal Data to comply with a legal requirement or to perform a contract with You, we will make this clear at the relevant time and advise You whether the provision of Your Personal Data is mandatory or not (as well as of the possible consequences if You do not provide Your Personal Data).

Similarly, if we collect and use Your Personal Data in reliance on our or a third party's legitimate interests and those interests are not already listed above (in the "Use of Your Personal Data" section), we will make clear to You at the relevant time what those legitimate interests are.

If You have questions about or need further information concerning the legal basis on which we collect and use Your Personal Data, please contact us using the contact details provided in "Contact Us" section below.

5. Third Party Transfers And Vendors

We may employ third party companies and individuals to facilitate our Service (“Vendors”), provide Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

5.1. Analytics

We may use third-party Vendors to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

Firebase

Firebase is analytics service provided by Google Inc.

You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en

For more information on what type of information Firebase collects, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

5.2. CI/CD tools

We may use third-party Vendors to automate the development process of our Service.

GitHub

GitHub is provided by GitHub, Inc.

GitHub is a development platform to host and review code, manage projects, and build software.

For more information on what data GitHub collects for what purpose and how the protection of the data is ensured, please visit GitHub Privacy Policy page:https://help.github.com/en/articles/github-privacy-statement.

5.3. Behavioral Remarketing

Miranna  uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

5.4. Payments

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• Stripe (https://stripe.com), and 
• Solowise (https://solowise.com)

5.5. Third Party Links and Websites.

Our Site and App may contain links to and from the websites of third parties. If you are a Visitor and follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.

We may also share certain Personal Data collected through the Services or generated by the System (e.g. online identifiers) with third party companies so that they may offer products and services that we believe will be of interest to You or with third party advertising-serving companies to better target the adverts and other content displayed on our site and to provide offers we think may be of interest to You. You may reject the use of Your Personal Data for marketing purposes anytime by contacting us using the contact details provided in “Contact Us” section below.

6. Data Retention 

We 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.

We will also retain the Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, 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. 

With regards to your invoices and Personal Data contained therein, we will hold them for 7 years from the invoice date due to legal obligations. We will delete all invoice data when the 7 year retention period has elapsed.

Premium Subscription data, including transaction records and refund history, will be retained for seven (7) years from the date of last transaction for legal compliance, accounting, and fraud prevention purposes.

7. Transfer of Data 

Any Personal Data that you provide to us may be accessed, shared or processed by our offices, located in the United States and EEA, and Vendors located in the United States and EEA, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract).

This may entail a transfer of your personal information across international borders. The data protections standards may differ and be lower than the standards enforced in your jurisdiction. We maintain appropriate safeguards as required by applicable law for any personal information transferred internationally, and as required by applicable law, will seek your consent prior to such transfers. 

8. Security

We employ multiple security measures to protect your personal information when you enter, submit, or access it. For instance, we use encryption for data transfer and storage whenever possible. Additionally, we restrict access to this data through access controls and confidentiality agreements.

However, no website, application, or data transmission can be completely secure. Therefore, while we have implemented what we believe are reasonable procedures to safeguard the confidentiality, security, and integrity of personal information collected through our Sites, we cannot guarantee the absolute security of any information you transmit to us.

9. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at info@miranna.com.

In certain circumstances, you have the following data protection rights:

• the right to access, update or to delete the information we have on you;
• the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
• the right to object. You have the right to object to our processing of your Personal Data;
• the right of restriction. You have the right to request that we restrict the processing of your personal information;
• the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
• the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

10. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/  

According to CalOPPA we agree to the following:

1. users can visit our site anonymously;
2. our Privacy Policy link includes the word “Privacy”, and can easily be found on the page specified above on the home page of our website;
3. users will be notified of any privacy policy changes on our Privacy Policy Page;
4. users are able to change their personal information by emailing us at info@miranna.com.

Our Policy on “Do Not Track” Signals:

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

11. Your Data Protection Rights under the California Consumer Privacy Act (CCPA)

If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:

1. What personal information we have about you. If you make this request, we will return to you:

• The categories of personal information we have collected about you.
• The categories of sources from which we collect your personal information.
• The business or commercial purpose for collecting or selling your personal information.
• The categories of third parties with whom we share personal information.
• The specific pieces of personal information we have collected about you.
• A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
• A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with. 

Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.

2. To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate. 

3. To stop selling your personal information. We do not sell your personal information for monetary consideration. However, under some circumstances, a transfer of personal information to a third party, or within our family of companies, without monetary consideration may be considered a “sale” under California law.

If you submit a request to stop selling your personal information, we will stop making such transfers. If you are a California resident, to opt-out of the sale of your personal information, click “Do Not Sell My Personal Information” at the bottom of our home page to submit your request.

Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances, we will discriminate against you for exercising your rights.

To exercise your California data protection rights described above, please contact us using the contact details provided in "Contact Us" section below

12. Policy Changes

We may change our Privacy Policy at any time. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version.

CONTACT US

If You have any questions or concerns regarding the use or disclosure of Your Personal Data through the Services, You can contact us by sending an email to info@miranna.com or sending an official request to the address below:

DealDep Corp.

220 East 23rd street, Suite 400, New York,

NY, 10010, United States of America