Privacy Policy

Version: 1.0
Effective Date: 1 June 2025

1. Introduction

Welcome to MannApp, a service delivered by Crafted Solutions Limited (“we,” “us,” “our”). We are committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, share, and protect your personal data when you use our MannApp platform, including its applications, websites, and related services (collectively, our “Services”).

Crafted Solutions Limited is the data controller for the personal data collected through our Services. Our details are:

Crafted Solutions Limited Company Number: 134630C Registered Address: Nelson House, 2 Prospect Hill, Douglas, IM1 1EJ, Isle of Man

Email for privacy inquiries: privacy@mann.app

This policy has been drafted in accordance with applicable data protection laws, including the Isle of Man Data Protection Act 2018 and the GDPR and LED Implementing Regulations 2018, the UK General Data Protection Regulation (UK GDPR), the UK Data Protection Act 2018, and specifically considers the UK Information Commissioner’s Office (ICO) Children’s Code (also known as the Age Appropriate Design Code).

2. What Information We Collect

We collect various types of personal information to provide and improve MannApp to you:

Information You Provide Directly:

Contact Information: Names, email addresses, phone numbers, physical addresses.
Account Information: Usernames, passwords, profile information (including professional information like job titles and company names) for your MannApp account.
Billing Information: Information necessary to process payments (e.g., billing address) for MannApp services. Please note that actual payment processing is handled by a third-party provider (to be determined), and we do not store full sensitive payment card details.
User-Generated Content: Profile pictures, posts, comments, and any other content you create or share on MannApp.
Communications: When you contact us for support, provide feedback, or make inquiries regarding MannApp.

Information Collected Automatically:

Usage Data: Information about how you use MannApp, such as features accessed, time spent, and interactions within the platform.
Device and Connection Information: IP addresses, device identifiers, browser type, operating system, and other technical information when you access MannApp.
Cookies and Similar Technologies: We use cookies and other tracking technologies to operate and personalize MannApp, and to analyse usage. Please see Section 7 (“Cookies and Tracking Technologies”) for more details.

Information from Third-Party Sources:

We may receive information about you from third-party sources, such as social media platforms if you use social logins for MannApp, public databases, or marketing partners, in accordance with their privacy policies and your permissions.

3. How We Use Your Information

We use your personal information for the following purposes related to MannApp:

To Provide and Maintain Our Services: Including creating and managing your MannApp account, delivering platform features, and providing customer support.
To Process Transactions: To facilitate payments for MannApp services through our third-party payment provider.
To Personalize Your Experience: To tailor content, recommendations, and features within MannApp to your interests and usage patterns (see Section 12 on Profiling).
For Communication: To send you service-related communications about MannApp (e.g., updates, security alerts, administrative messages), respond to your inquiries, and send optional marketing communications or notifications/subscriptions you have agreed to receive.
For Analytics and Improvement: To understand how MannApp is used, to monitor and analyse trends, and to improve the functionality and user experience of the platform.
For Security and Fraud Prevention: To protect the security and integrity of MannApp, our users, and our business, including detecting and preventing fraud, abuse, and security incidents on the platform.
To Enforce Our Terms: To enforce our Terms of Service and other policies applicable to MannApp.
To Comply with Legal Obligations: To meet legal and regulatory requirements, and to respond to lawful requests from public authorities.
To Manage Children’s Participation: For children using MannApp (see Section 6), to manage their participation in events and activities with parental consent and oversight.

We process your personal data based on the following legal grounds:

Contractual Necessity: To perform our contract with you, such as providing the core features of MannApp as described in our Terms of Service.
Consent: Where you have provided your explicit consent for specific processing activities, such as for certain types of cookies, optional marketing communications, or specific data uses related to children on MannApp. You can withdraw your consent at any time.
Legitimate Interests: For purposes such as improving MannApp, analytics, security, fraud prevention, and some forms of internal personalization/profiling, provided these interests are not overridden by your data protection rights.
Legal Obligation: When processing is necessary to comply with a legal or regulatory obligation to which we are subject.

We do not sell your personal information. We may share your personal information collected through MannApp with the following categories of third parties for the purposes described in this Privacy Policy:

Service Providers:

Payment Processors: (To be determined) To process payments for MannApp services.
Cloud Hosting Providers: To host our data and MannApp (e.g., Hetzner for servers in Germany).
Database Providers: (e.g., Xata) For data storage and management for MannApp.
Analytics Services: (e.g., Google Analytics) To help us understand MannApp usage.
Marketing Platforms: For managing communications and, where applicable, internal personalization on MannApp (we do not share with external ad networks for cross-site tracking).
Customer Support Tools: To manage and respond to user inquiries for MannApp.
Communication Tools: To facilitate email and other communications related to MannApp.

Partners:

Partners involved in delivering specific services offered on MannApp, such as event organisers or service providers (e.g., financial service providers offering quotes, as described in Section 12), where you have chosen to engage with such services through MannApp.

Legal and Professional Advisors:

Such as lawyers, auditors, and insurers, when necessary for legal, accounting, or security purposes.

Law Enforcement and Regulatory Bodies:

If required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of Crafted Solutions Limited, our MannApp users, or others.

If you choose to use social login features for MannApp.

Business Transfers:

In connection with a merger, acquisition, sale of assets, or other business restructuring, your information may be transferred as part of the transaction, subject to appropriate confidentiality and data protection safeguards.

When we share data with third parties, we take steps to ensure they use it in a manner consistent with this Privacy Policy and applicable laws.

6. Children’s Privacy and the Children’s Code

MannApp may include functionality that allows children to participate, for example, in attending events. We are committed to protecting children’s privacy and adhering to the standards of the UK ICO’s Children’s Code (Age Appropriate Design Code).

Definition of a Child:

For the purposes of this policy, we consider a “child” to be an individual under the age of 13 (aligning with the UK Data Protection Act 2018 age of consent for information society services, noting that parental consent is the basis for processing for children using MannApp).

Children can only use specific functionalities of MannApp as subsidiary users linked to a parent or guardian’s account.
Parents/guardians are responsible for adding their child(ren) to MannApp, which includes providing verifiable parental consent for the collection and processing of their child’s personal information for the purposes described.
Parents/guardians will have oversight and control over their child’s activities and data on MannApp.

Information Collected from Children:

We collect information necessary for the child’s participation via MannApp, as described in Section 2, always under parental consent. We do not collect sensitive personal information from children.

Use of Children’s Information:

Children’s personal information is used to enable their participation in MannApp services (e.g., event access), under parental guidance, and for the general purposes outlined in Section 3, as applicable and appropriate for children.

Children’s information may be shared with the categories of third parties listed in Section 5 only as necessary to provide the MannApp services they are participating in (e.g., event organisers, with parental awareness) and always in a manner that prioritizes the child’s safety and privacy.

Children’s Code Standards:

We are committed to designing and operating MannApp services that are likely to be accessed by children in line with the 15 standards of the Children’s Code. This includes, but is not limited to:

Prioritizing the best interests of the child.
Undertaking data protection impact assessments.
Providing age-appropriate application of this policy and other terms within MannApp.
Ensuring transparency.
Minimising data collection.
Not using detrimental profiling or nudge techniques.
Providing high privacy settings by default within MannApp.
Ensuring geolocation options are off by default unless strictly necessary for a service the parent has consented to and with appropriate safeguards.
Providing prominent and accessible tools within MannApp for users (including parents on behalf of their children) to exercise data protection rights.

Parents/guardians can review, update, or request deletion of their child’s personal information by contacting us at dataprocessing@mann.app.

7. Cookies and Tracking Technologies

We use cookies and similar technologies like web beacons or pixels on the MannApp website and applications.

What are Cookies?

Cookies are small text files stored on your device when you visit a website or use an app.

Types of Cookies We Use on MannApp:

Strictly Necessary Cookies: Essential for the operation of MannApp (e.g., to enable you to log in, maintain session security). These do not require consent but are explained to you.
Performance/Analytics Cookies: These help us understand how you use MannApp, such as which pages you visit and if you experience any errors (e.g., Google Analytics). This helps us improve MannApp.
Functionality/Preference Cookies: These are used to remember choices you make (e.g., your username, language, or region preferences within MannApp) and provide enhanced, more personal features.
Targeting/Personalization Cookies (Internal): We may use cookies or similar technologies to help us deliver personalized content or service offerings within MannApp from us or our direct partners on the platform, based on your interactions and preferences you express, and where you agree to such functionality (e.g., showing you relevant service providers). We do not use these cookies to track you across unrelated third-party websites or for external advertising networks.
Third-Party Cookies: Some cookies may be placed by third-party service providers, such as Google Analytics.

Your Choices:

When you first visit MannApp, you will be presented with a cookie consent banner allowing you to manage your preferences for non-essential cookies.
You can also usually modify your browser settings to refuse cookies or to alert you when cookies are being sent. However, if you disable cookies, some parts of MannApp may not function properly.

8. Data Security

We implement robust technical and organisational security measures to protect your personal information collected through MannApp from unauthorized access, use, alteration, disclosure, or destruction. These measures include:

Technical Measures:

Encryption of data at rest and in transit, access controls, multi-factor authentication, firewalls, and regular software updates and patching.

Organisational Measures:

Data minimisation principles, staff training on data protection, internal privacy policies, documented procedures for handling data breaches, and physical security of our premises.

While we strive to protect your personal information, no security system is impenetrable. We cannot guarantee the absolute security of your data transmitted to or stored on MannApp.

9. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected via MannApp, including:

As long as your MannApp account with us is active.
To provide you with our Services through MannApp.
To comply with our legal and regulatory obligations (e.g., for financial record-keeping, or as required by the Children’s Code).
To resolve disputes and enforce our agreements related to MannApp.

Different types of data may have different retention periods based on these criteria. Once personal information is no longer needed, we will securely delete or anonymize it.

10. International Data Transfers

Your personal information collected through MannApp may be transferred to, stored, and processed in countries other than your country of residence, including countries outside the Isle of Man and the UK/European Economic Area (EEA).

Our servers provided by Hetzner are located in Germany (within the EEA), which is recognised by the UK as providing an adequate level of data protection.
Services like Google Firebase may transfer data internationally, including to the United States. Google uses approved transfer mechanisms such as Standard Contractual Clauses (SCCs) or the UK’s International Data Transfer Agreement (IDTA)/Addendum to safeguard such transfers.
Our database provider, Xata, may also process data in various locations. We rely on Xata’s contractual commitments and data processing agreements to ensure appropriate safeguards (such as SCCs/IDTA) are in place for any international transfers of data from the UK/EEA. You should refer to Xata’s privacy policy and DPA for specific details on their data processing locations.

Where we transfer your data outside the Isle of Man/UK/EEA to a country not deemed adequate, we will ensure appropriate safeguards are in place as required by applicable data protection laws.

11. Your Data Protection Rights

Under data protection laws applicable in the Isle of Man and the UK (including GDPR and UK GDPR), you have various rights regarding your personal information in relation to MannApp. These include the right to:

Access: Request a copy of the personal information we hold about you.
Rectification: Request correction of inaccurate or incomplete personal information.
Erasure (Right to be Forgotten): Request deletion of your personal information under certain conditions.
Restriction of Processing: Request that we restrict the processing of your personal information under certain conditions.
Data Portability: Request to receive your personal information in a structured, commonly used, and machine-readable format, and to have it transmitted to another controller where technically feasible.
Object to Processing: Object to the processing of your personal information where it is based on our legitimate interests or for direct marketing purposes.
Withdraw Consent: Withdraw your consent at any time where our processing is based on your consent. This will not affect the lawfulness of processing based on consent before its withdrawal.
Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority.

Complaint Contacts:

In the Isle of Man: Isle of Man Information Commissioner, P.O. Box 69, Douglas, Isle of Man, IM99 1EQ. (www.inforights.im)
In the UK: Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. (www.ico.org.uk)

To exercise any of these rights in relation to your data on MannApp (or if you are a parent/guardian wishing to exercise rights on behalf of your child), please contact us at: dataprocessing@mann.app. We will respond to your request in accordance with applicable data protection laws.

12. Automated Decision-Making and Profiling on MannApp

We may use profiling on MannApp for content personalization or targeted recommendations within our platform. For example:

If you express interest in certain types of services (e.g., financial services from a provider like “ABC Bank” who is a partner on MannApp), we may use information you provide or your activity on MannApp to highlight such services to you. This is done to make MannApp more relevant to you.
This profiling is based on your interactions and, where applicable, specific functionalities you agree to use within MannApp.

We do not use automated decision-making that produces legal effects or similarly significantly affects you without human intervention, unless permitted by law and with appropriate safeguards. You have the right to object to profiling in certain circumstances.

This profiling is for internal personalization on MannApp and connecting you with services on our platform; we do not track your activity across unrelated external websites for these purposes.

13. Managing Your Preferences and Opt-Outs on MannApp

You have choices regarding the communications you receive from us in relation to MannApp:

Marketing Emails: You can opt-out of receiving optional marketing emails by using the “unsubscribe” link provided in such emails or by adjusting your preferences in your MannApp account settings.
Notification/Subscription Emails: You can manage your preferences for other optional notifications and subscriptions through your MannApp account settings.
Core System Emails: Please note that you generally cannot opt-out of essential service-related communications about MannApp (e.g., security alerts, account verification, or critical updates to the Services), as these are necessary for us to provide the Services to you.
Cookie Preferences: You can manage your cookie preferences via the cookie consent banner on the MannApp website/webapp and through your browser settings.

14. Third-Party Websites/Links

MannApp may contain links to other websites or services not operated or controlled by us (“Third-Party Sites”). The information that you share with Third-Party Sites will be governed by the specific privacy policies and terms of service of the Third-Party Sites and not by this Privacy Policy. We do not endorse and are not responsible for the practices of Third-Party Sites.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices for MannApp, legal requirements, or service offerings. We will notify you of any material changes through a combination of methods, which may include:

Posting the updated policy on the MannApp website and/or app with a new effective date.
Sending an email notification to registered MannApp users.
Displaying an in-app or on-site notification within MannApp.

We encourage you to review this Privacy Policy periodically. Your continued use of MannApp after the effective date of any revised Privacy Policy will constitute your acceptance of the changes, subject to applicable law.

16. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data handling practices for MannApp, or if you wish to exercise your data protection rights, please contact us:

Crafted Solutions Limited Attn: Privacy Officer Nelson House, 2 Prospect Hill, Douglas, IM1 1EJ, Isle of Man Company Number: 134630C

Email: privacy@mann.app

For specific requests regarding data processing rights, please use: dataprocessing@mann.app