Privacy Policy

This Agreement was last updated on 1 August 2017. 

MIRACL UK LIMITED ("we", “us”, “our”) is committed to protecting and respecting your privacy.



This policy applies to your use of:

  • the MIRACL Trust mobile application software (the “App) available on our site and also hosted on the Google Play Store and Apple App Store (the “App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (“Device); and
  • any of the services accessible through the App (“Services) that are available on the App Site or other sites of ours (“Services Sites).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998 (the “Act”) and any laws that replace or amend the Act from time to time (including without limitation the General Data Protection Regulation 2016 (Regulation (EU) 2016/679)) (“Data Protection Law”), the data controller is MIRACL UK LIMITED of 81 Rivington Street, London, EC2A 3AY.


We will collect and process the following data about you (each together constitution “your information”):

Information you give us (“Submitted Information”): This is information you give us by filling in forms on the App Site and/or the Services Sites (together the “Sites”), or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use the App Site, download or register the App, subscribe to any of our Services, search for the App or a Service and when you report a problem with the App, our Services, or any of the Sites. If you contact us, we will keep a record of that correspondence. The information you give us may include (without limitation) your name, address, e-mail address and phone number, the Device's phone number, age, username, password and other registration information, financial and credit card information, personal description and photograph.

Information we collect about you and your Device. Each time you visit one of our Sites or use the App we will automatically collect the following information:

  • technical information, including the type of Device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and the time zone setting (“Device Information”);
  • information stored on your Device, including contact information, friends lists, login information, photos, videos or other digital content (“Content Information”); and
  • details of your use of any of our Apps or your visits to any of our Sites including, but not limited to traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access (“Log Information”).
  • Location information. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by contacting us at privacy@miracl.com.
  • Information we receive from other sources (“Third Party Information”). We are working closely with carefully selected third parties (including, without limitation, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
  • Unique application numbers: when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.


We use cookies to distinguish you from other users of the App, App Site or Services Site. This helps us to provide you with a good experience when you use the App or browse any of the sites and also allows us to improve the App and the Sites. For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy a copy of which can be located at https://www.miracl.com/miracl_cookie_policy.


We use your information in the following ways:

  • Submitted Information:
    • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
    • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about, where we have your consent to do so;
    • to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods or services similar to those which were the subject of a previous sale or negotiations of a sale to you, unless you have told us that you do not want to receive such information. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data or contact us at privacy@miracl.com;
    • to notify you about changes to our service; and
    • to ensure that content from the App or any of our Services is presented in the most effective manner for you and for your Device.
  • Device Information, Content Information and Log Information:
    • to administer our the App, Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • to improve the App and the Services to ensure that content is presented in the most effective manner for you and for your computer;
    • to allow you to participate in interactive features of our App or our Services, when you choose to do so;
    • as part of our efforts to keep the App and the Services safe and secure;
    • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
    • to make suggestions and recommendations to you and other users of the App and/or our Services about goods or services that may interest you or them, in accordance with the provisions of this privacy policy.
  • Location Information and Third Party Information: We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this privacy policy for as long as it is combined.

We do not disclose your information to our advertisers, but we may provide them with anonymous aggregated information about our users.


You agree that we have the right to share your information with:

  • any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006;
  • carefully selected third parties including:
    • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
    • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience; and 
  • analytics and search engine providers that assist us, for the legitimate interest of improvement and optimisation of the App and Services.

We will also disclose your information to third parties:

  • in the event that we sell or buy any business or assets, in which case we will disclose your information to the prospective seller or buyer of such business or assets;
  • if we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
  • if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request; or
  • for our legitimate interests in order to:
    • enforce or apply our terms and conditions located at https://www.miracl.com/miracl-terms-and-conditions and other agreements or to investigate potential breaches; or
    • protect the rights, property or safety of our customers, or others (including without limitation exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).


The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services. By submitting your information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your data transmitted to the Sites and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We will collect and store personal data on your Device using application data caches and browser web storage and other technology.


You can access and rectify certain parts of your personal information by logging into your account.

Under Data Protection law, you have the right to:

  • see the personal information that we hold about you, whether collected through your use of the App and/or the Services or through any communications that you have had with us;
  • access your information;
  • rectify your information (including without limitation the erasure of certain of your information);
  • obtain and reuse your information for your own purposes across different services; and
  • ask us not to process your information (or pass your information to other companies or organisations) for marketing purposes and you can tick the appropriate box on the forms when we collect your information or later at any time by contacting us at privacy@miracl.com.

To access and rectify your information in accordance with this policy, please send us a written request to privacy@miracl.com.

If you have a complaint about how we have used your information, you have the right to complain to the Information Commissioner’s Office.


Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.


Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@miracl.com.