Minerva Privacy Policy

Last Updated: March 31, 2025

This Privacy Policy is designed to help you understand how Minerva BI Inc. (“Minerva”, “we”, “us”, or “our”) collects, uses, processes, and shares your personal information and to help you understand and exercise your privacy rights.

Notice at Collection

At or before the time of collection, California residents have a right to receive notice of Minerva’s privacy practices, including the categories of personal information to be collected, the purposes for which such information is collected or used, whether such information is “sold” or “shared”, and how to opt-out of such uses, and how long such information is retained.

Privacy Policy Table of Contents

• 1. SCOPE OF THIS PRIVACY POLICY
• 2. UPDATES TO THIS PRIVACY POLICY
• 3. PERSONAL INFORMATION WE COLLECT
• 4. HOW WE USE PERSONAL INFORMATION
• 5. HOW WE DISCLOSE PERSONAL INFORMATION
• 6. YOUR PRIVACY CHOICES AND RIGHTS
• 7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
• 8. RETENTION OF PERSONAL INFORMATION
• 9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
• 10. CHILDREN’S INFORMATION
• 11. THIRD-PARTY WEBSITES/APPLICATIONS
• 12. CONTACT US

1. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed by us, including on our websites and other online or offline offerings. To make this Privacy Policy easier to read, our websites and other offerings are collectively called the "Services".

DESIGNATED METHODS FOR SUBMITTING DATA SUBJECT REQUESTS

Minerva has designated the following methods for submitting consumer requests under the CCPA, including access, correction, deletion, and opt-out of sale or sharing:

• Webform: preferences.minerva.io
• Toll-Free Number: +1 (888) 857-5775
  (This number provides a recorded message directing requestors to the webform.)

To ensure secure and efficient processing, Minerva only processes data subject requests submitted via these designated methods. Requests sent to other channels, including email, will receive an automatic response redirecting to the webform.
For general inquiries unrelated to data subject rights, contact: [email protected]

2. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Policy on our website and/or we may also send other communications.

3. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we obtain automatically when you use the Services, and personal information from third-party sources as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

Account Information. We may collect personal information in connection with the creation or administration of your account such as your name, email address, phone number, professional details, and other information.

Payments. We may collect personal information and details associated with your purchases of services, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (for example, your billing details).

Your Communications with Us. We may collect personal information such as your email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.

Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.

Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public.”

Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.

Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

Job Applications. If you apply for a job with us, we will collect any personal information you provide with your application, such as your contact information and CV.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use the Services.

Automatic Collection of Personal Information. We may collect certain personal information automatically when you use the Services, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit, items that you search for via the Services, information about the links you click, the frequency and duration of your activities, and other information about how you use our Services.

Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of the Services.

Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

C. Personal Information Collected from Other Sources

Third-Party Services. We may obtain personal information about you from other services, including through third-party services. For example, if you access our Services through a third-party login service, we may collect personal information about you from that third-party service that you have made available via your privacy settings.

Third-Party Sources. We may obtain personal information about you from third-party sources, such as Minerva customers that submit personal information to us, databases of publicly available records, data brokers, and other third-party providers of personal information. In some cases, we may restrict our use and disclosure of personal information provided by a Minerva customer in accordance with the agreement we have executed with such customer.

Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (for example, relative, friend, neighbor, or co-worker).

4. HOW WE USE PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide The Services

We use personal information to fulfill our contract with you and provide the Services, such as:

• Inferring and/or deriving characteristics, attributes, insights, interests, and estimates regarding individuals (e.g., estimated income, estimated net worth, etc.);
• Compiling and selling personal information to third parties;
• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support;
• Communicating with you about your account, activities on our Services, and policy changes;
• Processing your financial information and other payment methods for products or Services purchased;
• Processing applications if you apply for a job we post on our Services; and
• Allowing you to register for events.

B. Administrative Purposes

We use personal information for various administrative purposes, such as:

• Pursuing our legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Carrying out analytics;
• Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information unless permitted by or required to comply with applicable laws;
• Measuring interest and engagement in our Services;
• Short-term, transient use, such as contextual customization of ads;
• Improving, upgrading, or enhancing our Services;
• Developing new products and services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing personal information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

C. Marketing

We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

D. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

E. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

5. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide the Services

The categories of third parties with whom we may share your personal information are described below.

• Third Parties We Sell or Disclose Personal Information To: We may sell or disclose personal information to third parties in exchange for monetary or other valuable consideration.
• Service Providers: We may share your personal information with our third-party service providers and vendors that assist us with the provision of the Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.
• Business Partners: We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
• Affiliates: We may share your personal information with our company affiliates.
• Minerva Customers (Authorized Users Only): In cases where you use our Services as an employee, contractor, or other authorized user of a Minerva customer, that customer may access information associated with your use of the Services, including usage data and the contents of the communications and files associated with your account. Your personal information may also be subject to the Minerva custome’s privacy policy. We are not responsible for the Minerva custome’s processing of your personal information.
• Advertising Partners: We may share your personal information with third-party advertising partners. These third- party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (for example, your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “targeted advertising,” “personalized advertising,” or “cross-context behavioral advertising.”

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

6. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices

The privacy choices you may have about your personal information are determined by applicable law and are described below.

Your Privacy Rights

In accordance with applicable law, you may have the right to:

• Confirm Whether We Are Processing Your Personal Information (the right to know);
• Request Access to and Portability of Your Personal Information, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine-readable format (also known as the “right of data portability”);
• Request Correction of your personal information where it is inaccurate or incomplete;
• Request Deletion of your personal information;
• Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws);

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us”. We will process such requests in accordance with applicable laws.

To protect your privacy, we will take commercially reasonable steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

Acknowledgment and Timing of Requests

• We will acknowledge receipt of access, deletion, or correction requests within 10 business days.
• We will respond within 45 calendar days. If an extension is needed, we may take up to an additional 45 days with notice during the original response period.
• We will respond to opt-out of sale/sharing requests within 15 business days.

Verfication and Authorized Agents

• For access, deletion, and correction, we will verify your identity using reasonable methods.
• For authorized agents, we require written authorization but will not require the consumer to confirm directly for opt-out requests.

Recordkeeping

• We maintain records of consumer requests for at least 24 months, including:
• Date of request
• Type of request
• Submission method
• Response date
• Outcome and reason for denial (if applicable)

7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries which may have data protection laws that are different from the laws where you live.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

8. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Notice for California Residents supplements our Privacy Policy and only applies to our processing of personal information that is subject to this Privacy Policy and the California Consumer Privacy Act of 2018 (as amended from time to time) (“CCPA”).

The CCPA provides California residents with the right to know what categories of personal information Minerva has collected about them whether Minerva disclosed that personal information for a business purpose (e.g. to a service provider) whether Minerva “sold” that personal information and whether Minerva “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using and disclosing personal information are set forth in “Personal Information We Collect”, “How We Use Personal Information”, and “How We Disclose Personal Information” above, respectively. We will retain personal information in accordance with the time periods set forth in “Retention of Personal Information.”

If applicable from the table above, we “sell” and “share” your personal information:

• to provide you with “cross-context behavioral advertising” about Minerva’s products and services; and
• to provide our third parties that we sell, share, or otherwise disclose personal information to with enriched personal information for their sales, marketing, and other business purposes.

Additional Privacy Rights for California Residents

Opting Out of “Sales” of Personal Information and/or “Sharing” for Cross-Context Behavioral Advertising under the CCPA.

Disclosure Regarding Individuals Under the Age of 16. Minerva does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. Minerva does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”

Disclosure Regarding Sensitive Personal Information

Minerva only uses and discloses sensitive personal information for the following purposes:

• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
• To resist malicious, deceptive, fraudulent, or illegal actions directed at Minerva and to prosecute those responsible for those actions.
• To ensure the physical safety of natural persons.
• To verify or maintain the quality or safety of Minerva products, services, or devices, and to improve, upgrade, or enhance Minerva’s services or devices.
• For purposes that do not infer characteristics about individuals.

Non-Discrimination

California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

Annual Data Broker Disclosure Metrics (2024)

10. CHILDREN’S INFORMATION

The Services are not directed to children under 18 (or other age as required by local law) and we do not knowingly collect personal information from children. If you believe that we have inadvertently collected personal information from a child under the age of 18, please contact us as set forth in “Contact Us.”

11. THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

12. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Minerva BI Inc.
200 Broadway, Floor 3
New York, NY 10038
[email protected]