MYNE PRIVACY POLICY
Version 1.0 – Last updated: 2 October 2026
This Privacy Policy explains how Mynehub Ventures, S.L. (“MYNE”, “we” or “us”) processes personal data as controller, in accordance with Regulation (EU) 2016/679 (the “GDPR”) and Spanish Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (the “LOPDGDD”).
1. WHO IS THE CONTROLLER
Controller: Mynehub Ventures, S.L., a Spanish company with Tax ID B16877714 and registered office at Príncipe de Vergara 112, 28002 Madrid, Spain.
Contact for data protection matters: privacy@mynegroup.com.
Data Protection Officer: MYNE has appointed a Data Protection Officer, who can be contacted at privacy@mynegroup.com.
2. SCOPE OF THIS POLICY
This Privacy Policy applies to the personal data that MYNE processes as controller in relation to:
- visitors to our website www.mynegroup.com (the “Website”);
- persons who contact us by e-mail or by any other means;
- representatives, employees and contact persons of our clients, prospective clients, suppliers and business partners; and
- candidates who send us their CV or apply for a position at MYNE.
Services provided to our clients. This Privacy Policy does not apply to the personal data that MYNE processes on behalf of its clients when providing its services (including data engineering, analytics and predictive modelling). In that case, MYNE acts as processor and the relevant client (or its own client) is the controller. That processing is governed by the agreement with the client, including the MYNE Data Protection Agreement, and by the privacy notice of the controller. If your personal data is processed in this context, please contact the relevant controller to exercise your rights; if you contact us, we will forward your request to it.
3. WHAT PERSONAL DATA WE PROCESS
Depending on your relationship with us, we may process the following categories of personal data:
- Identification and contact data: name, surname, job title, company, business e-mail address and telephone number.
- Content of communications: the information you include in your messages to us.
- Contractual and billing data: data relating to the representatives and contact persons of clients and suppliers that are necessary to execute and manage the contract, such as signature, powers of representation and invoicing details.
- Professional and academic data of candidates: CV, education, professional experience and any other information you decide to share with us.
- Technical data: IP address, browser type, device, date and time of access and pages visited, collected through server logs and strictly necessary cookies when you visit the Website.
We do not request special categories of personal data. Please do not include them in your communications or CV.
4. PURPOSES, LEGAL BASES AND RETENTION
| Purpose | Legal basis | Retention period |
|---|---|---|
| Responding to enquiries and requests sent to us by e-mail or by any other means. | Our legitimate interest in responding to the communications we receive (Art. 6.1(f) GDPR) and, where applicable, taking steps at your request before entering into a contract (Art. 6.1(b) GDPR). | For the time necessary to handle the enquiry and up to twelve (12) months thereafter, unless a business relationship is established. |
| Managing the business relationship with our clients, suppliers and partners, including communications with their representatives and personnel. | Performance of a contract where you are a party to it (Art. 6.1(b) GDPR); otherwise, our legitimate interest in maintaining the relationship with the organisation you represent or work for (Art. 6.1(f) GDPR and Art. 19 LOPDGDD). | For the duration of the relationship and, thereafter, duly blocked for the applicable limitation periods. |
| Invoicing, accounting, tax and other legal obligations. | Compliance with legal obligations (Art. 6.1(c) GDPR). | For the periods required by law (for example, six (6) years under Article 30 of the Spanish Commercial Code). |
| Sending information about MYNE’s services, events and news to business contacts. | Our legitimate interest in promoting our services to existing clients, in respect of services similar to those previously contracted, as permitted by Article 21.2 of Spanish Law 34/2002 (Art. 6.1(f) GDPR); otherwise, your consent (Art. 6.1(a) GDPR). | Until you object or withdraw your consent. Every communication includes a simple way to unsubscribe. |
| Managing job applications and selection processes. | Taking steps at your request before entering into a contract (Art. 6.1(b) GDPR) and, to keep your CV for future vacancies, your consent (Art. 6.1(a) GDPR). | For the duration of the selection process and, with your consent, up to twelve (12) months thereafter. |
| Operating the Website and ensuring its security. | Our legitimate interest in providing a secure and functioning Website (Art. 6.1(f) GDPR). | Server logs are generally kept for no more than twelve (12) months, unless required to investigate a security incident. |
| Handling requests to exercise data protection rights and the formulation, exercise or defence of legal claims. | Compliance with legal obligations (Art. 6.1(c) GDPR) and our legitimate interest in defending our rights (Art. 6.1(f) GDPR). | Up to three (3) years after the request has been answered or, for claims, for the applicable limitation periods. |
Where we rely on our legitimate interest, we have assessed that it is not overridden by your interests or fundamental rights and freedoms. You may object to such processing at any time, as explained in Section 9.
Where processing is based on your consent, you may withdraw it at any time, without affecting the lawfulness of the processing carried out before its withdrawal.
5. SOURCE OF THE DATA
We obtain personal data directly from you or, where you are a representative or contact person of a client, supplier or partner, from the organisation you represent or work for (for example, when it designates you as a contact person in an order or contract). We may also obtain professional contact data from publicly available professional sources for the purposes of business development, in which case we will inform you in our first communication.
6. RECIPIENTS
We do not sell personal data. We may share personal data with:
- Service providers acting as processors on our behalf, under a written contract and our instructions, including providers of e-mail, productivity and collaboration tools (Microsoft), cloud hosting services (Amazon Web Services) and other IT services, as well as professional advisers (legal, tax and audit) bound by confidentiality obligations.
- Banks and financial institutions, for the management of payments and collections.
- Public authorities, courts and tribunals, where required by law.
- Potential acquirers, investors or successors, in the context of a corporate transaction (such as a merger, acquisition or restructuring), subject to appropriate confidentiality safeguards.
7. INTERNATIONAL TRANSFERS
Some of our service providers may process personal data outside the European Economic Area, for example in the United States. In such cases, transfers are based on an adequacy decision of the European Commission (including the EU-U.S. Data Privacy Framework for certified recipients) or on the standard contractual clauses approved by the European Commission, together with any supplementary measures required. You may request further information on the safeguards applied by writing to privacy@mynegroup.com.
8. COOKIES
The Website only uses technical cookies that are strictly necessary for its operation, which are exempt from consent under Article 22.2 of Spanish Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce. If we use analytics, advertising or other non-essential cookies in the future, we will request your prior consent through a cookie banner and publish a Cookie Policy.
9. YOUR RIGHTS
You have the right to:
- access your personal data;
- request the rectification of inaccurate data or the erasure of your data;
- request the restriction of the processing of your data;
- object to the processing of your data based on our legitimate interest, including direct marketing;
- receive your data in a structured, commonly used and machine-readable format and have it transmitted to another controller (portability), where applicable; and
- withdraw your consent at any time, where processing is based on consent.
To exercise your rights, please write to privacy@mynegroup.com, indicating the right you wish to exercise. Where we have reasonable doubts about your identity, we may ask you for additional information to confirm it. We will reply within one (1) month, which may be extended by two (2) further months where necessary, taking into account the complexity and number of requests.
You also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, C/ Jorge Juan 6, 28001 Madrid, www.aepd.es). We would, however, appreciate the opportunity to address your concerns first.
10. AUTOMATED DECISIONS
MYNE does not take decisions based solely on automated processing, including profiling, which produce legal effects concerning or similarly significantly affect the persons covered by this Privacy Policy.
11. SECURITY
MYNE applies appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access, taking into account the state of the art, the costs of implementation and the risks involved.
12. MINORS
The Website and our services are addressed to businesses and professionals. We do not knowingly process personal data of persons under fourteen (14) years of age.
13. DATA OF THIRD PARTIES
If you provide us with personal data of other persons (for example, colleagues designated as contact persons), you must ensure that you are entitled to do so and that you have informed them of this Privacy Policy.
14. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. The current version and its date are always indicated at the top of this document. Where changes are significant, we will inform you by appropriate means.