Privacy Policy

Last modified on October 2023

This Privacy Policy explains how Mushi Lab collects, uses, shares, and protects personal information, and the privacy rights and choices we offer, in connection with our websites, online services, and products and services (collectively, our “Services”). 

Personal Information We Collect

Information you provide to us. Personal information you may provide to us includes:
  • Contact details, such as your first and last name, organization name, email and mailing addresses, and phone number.
  • Account data, such as the username and password that you may use to establish an online account with us.
  • Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
  • Order and purchase history, including your interactions with our checkout page.
  • Payment details, such as your payment card number, bank account number and shipping address. We rely on payment providers, such as Stripe, to process payments and we do not have access to payment card numbers.
  • Subscriber survey data, including the information you provide when you fill out surveys, and recordings of video or voice chats with our marketing team. 
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
  • Data providers, such as information services, data co-ops, and data licensors.
  • Public sources, such as social media platforms.
  • Marketing partners, such as companies that have entered into joint marketing relationships with us.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with our websites, online services and our communications, such as:
  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our websites, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.
Cookies and similar technologies. Our Services may use the following technologies:
  • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser, in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
How We Use Personal Information
We use personal information for the following purposes:
Service delivery. We use personal information to perform our contractual obligation under our terms of use, including to:
  • Provide, operate and improve our Services and our business;
  • Process your payments and complete transactions with you; and
  • Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages.
Improve, monitor, personalize, and protect our Services. It is in our legitimate business interests to improve and keep our services safe for our users, which includes:
  • Understanding your needs and interests, and personalizing your experience with the Services and our communications; 
  • Engaging in surveys and recording our video and audio chats with consumers;
  • Troubleshooting, testing and research to keep the services secure; and
  • Investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.
Research and development. We may use  personal information for research and development purposes in our legitimate business interests, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.
Marketing and advertising. We, our service providers, and our third party advertising partners may collect and use  personal information for the following marketing and advertising purposes:
  • Direct marketing. We may send you Mushi Lab-related direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing section.
  • Interest-based advertising. We may engage third party advertising companies and social media companies to display ads on our websites and other online services. These companies may use cookies and similar technologies to collect information about your interactions (including the data described in the “Automatic data collection” section) over time across our Services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to them or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the “Your Choices” section below.
Except where consent is required, we undertake such marketing and advertising on the basis of our legitimate business interest. Where we seek your consent, you may withdraw your consent at any time.
Compliance and protection. We may use  personal information to comply with legal obligations, and to defend us against legal claims or disputes, including:
  • Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • Enforce the terms and conditions that govern our Services;
  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

How We Use Personal Information

We use personal information for the following purposes:

Service delivery. We use personal information to perform our contractual obligation under our terms of use, including to:
  • Provide, operate and improve our Services and our business;
  • Process your payments and complete transactions with you; and
  • Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages.
Improve, monitor, personalize, and protect our Services. It is in our legitimate business interests to improve and keep our services safe for our users, which includes:
  • Understanding your needs and interests, and personalizing your experience with the Services and our communications; 
  • Engaging in surveys and recording our video and audio chats with consumers;
  • Troubleshooting, testing and research to keep the services secure; and
  • Investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.
Research and development. We may use  personal information for research and development purposes in our legitimate business interests, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.
Marketing and advertising. We, our service providers, and our third party advertising partners may collect and use  personal information for the following marketing and advertising purposes:
  • Direct marketing. We may send you Mushi Lab-related direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing section.
  • Interest-based advertising. We may engage third party advertising companies and social media companies to display ads on our websites and other online services. These companies may use cookies and similar technologies to collect information about your interactions (including the data described in the “Automatic data collection” section) over time across our Services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to them or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the “Your Choices” section below.
Except where consent is required, we undertake such marketing and advertising on the basis of our legitimate business interest. Where we seek your consent, you may withdraw your consent at any time.
Compliance and protection. We may use  personal information to comply with legal obligations, and to defend us against legal claims or disputes, including:
  • Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • Enforce the terms and conditions that govern our Services;
  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

How We Share Personal Information

We may share personal information with:
Affiliates. Within Mushi Lab for purposes consistent with this Privacy Policy

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, survey platform providers and website analytics services). 

Payment processors. When you make a purchase at Mushi Lab, your payment card information is collected and processed directly by our payment processors, such as Stripe. We do not record or maintain payment card or bank account details. These payment processors may use your payment data in accordance with their privacy policies. Stripes’s privacy policy is available at https://stripe.com/privacy
Facebook and other Social Networking Services. You may be given the option to access or register for the Services through the use of your user name and passwords provided by Facebook and other social networking sites (each, an “SNS”), or otherwise have the option to connect an SNS account. By doing so, you authorize us to access and store information from the SNS -- including, without limitation, your name, email address(es), date of birth, gender, current city, profile picture and URL -- and to use and disclose it in accordance with this Privacy Policy. To control what information is shared with us, please check your privacy settings on each SNS and make changes as appropriate. 

Third parties. Third parties, such as advertising companies, data providers and data co-ops, such as Oracle and Epsilon, for interest-based advertising and other marketing purposes, including those third parties’ own purposes. To learn how to opt-out, please see the “Privacy Rights and Choices” section below. 

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us. 

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Mushi Lab (including, in connection with a bankruptcy or similar proceedings).
Privacy Rights and Choices
Account choices. If you have a Mushi Lab account, you can review and update certain account information by logging into your account. Registered users may also contact us to request deletion of their account and certain personal information. 

Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the emails you receive from us. You may continue to receive service-related and other non-marketing emails.
Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information: 
  • Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
  • Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
  • Correction of personal information that is inaccurate or out of date.
  • Deletion of personal information that we no longer need to provide the services or for other lawful purposes.
  • Additional rights, such as to object to the processing of your personal information for our legitimate business interests or any marketing related purposes, and to request that we restrict our use of personal information.
To make a request, please write to us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity. You are entitled to exercise the rights described above free from discrimination.

Depending on your jurisdiction, you may designate an “authorized agent” to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. 

In addition, you can limit the use of tracking technologies, such as cookies, by following the instructions in the “Online tracking opt-out” section below.

Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. 
Complaints. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below. If you are based in certain jurisdictions, you may lodge a complaint about how we handle your personal information with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit www.allaboutdnt.com.

Online tracking opt-out. There are a number of ways to limit the tracking of your online activity and collection of device data through automated means, which we have summarized below:
  • Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
  • Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
  • Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt-out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
  • Updating your SNS settings. To stop sharing your information with Facebook and other SNS with whom Mushi Lab permits you to connect your account, please modify your privacy settings on those platforms.  

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of  personal information.

Children

Our Services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through our Services from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.

Retention of Personal Information

We retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable). 
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

Use of Customer Interactions and Image Release

Lawful Basis and Consent. The Company may process customer interactions, including reviews, testimonials, feedback, videos, and other forms of communication, for the purposes of advertising and promotional activities. Such processing shall be based on the lawful basis of consent, whereby Customers provide explicit and voluntary consent for the Company to use their interactions.

Purpose Limitation. The Company shall use customer interactions solely for the purposes of advertising and promoting its products or services. This includes the right to utilize the interactions to showcase the quality of its products or services, subject to the conditions outlined in this Clause.

Image Release. Customers grant the Company the right to use their name, image, and likeness, as provided by them, for advertising and promotional purposes. Customers acknowledge that, in principle, the Company shall not be obligated to provide any financial compensation for the use of their name and image. However, the Company shall ensure that the use of Customers' images complies with applicable laws and regulations, and any additional compensation shall be subject to a separate written agreement.
Withdrawal of Consent. Customers have the right to withdraw their consent for the Company to use their interactions and image at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Customers may exercise their right to withdraw consent by contacting the Company as specified in the Agreement or the Company's Privacy Policy.

Data Protection and Security. The Company shall implement appropriate technical and organizational measures to ensure the security and protection of customer interactions, including safeguarding against unauthorized access, loss, destruction, alteration, or disclosure. The Company shall process customer interactions in accordance with its Privacy Policy and applicable data protection laws.

Retention Period. Customer interactions shall be retained only for as long as necessary to fulfill the purposes outlined in this Clause, unless a longer retention period is required or permitted by law. Once the interactions are no longer necessary, the Company shall securely delete or anonymize them.

Data Subject Rights. Customers have the right to exercise their data subject rights as provided by applicable data protection laws, including the right to access, rectify, erase, restrict processing, and object to the processing of their personal data. Customers may contact the Company to exercise these rights.
Data Transfers. The Company may transfer customer interactions and related data to third parties, including affiliates or service providers, solely for the purposes outlined in this Clause. The Company shall ensure that any such transfers comply with applicable data protection laws and appropriate safeguards are in place.

Modifications and Termination. The Company reserves the right to modify or terminate the use of customer interactions and image release, provided that such modifications or terminations will not affect any prior use of customer interactions or images made by the Company in accordance with this Clause.

 

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our websites and online services. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through our Services. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of our Services after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to Contact Us

Mushi Lab OÜ. is the entity responsible for the processing of personal information and is the data controller in respect of such processing. You can reach us by email at mushi@mushilab.com or at the following postal addresses:
Mushi Lab OÜ,
Calle Nuñez de Balboa 8,
Bajo Izquierda,
28002, Madrid, Spain