Privacy policy

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Last updated: December 10, 2024

Mojo Men Ltd (“Mojo,” “we,” “us,” or “our”) has prepared this Privacy Policy to explain what Personal Data (defined below) we collect through your use of mojo.so (the “Website”) (including the contributions in the discussion forums), how we use and share that data, and your choices concerning our data practices. However, we process your Personal Data based on several lawful bases, not only contract. Please read this Privacy Policy for full information about how we process your personal data. This Privacy Policy is incorporated into and forms part of our Terms of Use.

For the purpose of the GDPR, the UK GDPR and the Data Protection Act 2018, we are the data controller. This Privacy Policy applies to our users’, partners’, website visitors and prospects’ data to the extent it pertains to natural persons. Before using the Website or submitting any Personal Data to Mojo, please review this Privacy Policy carefully and contact us if you have any questions. By using the Website, you understand the practices described in this Privacy Policy. If you do not understand this Privacy Policy, please contact us, and do not access the Website, register for a user account, or otherwise use the Website.

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1. Personal Data we Collect

2. Cookies
3. How we process Personal Data
4. Sharing and Disclosure of Personal Data
5. Update your Information
6. Children
7. Profiling and use of Artificial Intelligence
8. Third-party links
9. Security
10. Additional information
11. Your rights
12. Data Retention
13. Changes to the Privacy Policy
14. Contact Us

1. Personal Data we Collect

We collect the following categories of information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”): 

User Account Data: When you create an account, we will collect the information needed to authenticate your access to the Website, this may include but is not limited to name, username, and email address.  

Financial Data: To the extent any features of the Website are available for a fee, we may collect the financial information necessary to process your payments, such as your payment card number and authentication details. 

Communication Data: We may collect information when you contact us with questions or concerns and when you voluntarily contribute to discussion forums, respond to questionnaires, surveys or requests for market research seeking your opinion and feedback. Providing this information is optional to you. 

Social Media Data: We have pages on social media sites like Facebook, Twitter, and Instagram (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages. 

Internet Activity Data: When you visit, use, and interact with the Website, we may automatically receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Website, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Website (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:  


• Log data: Information that your browser automatically sends whenever you visit the Website (“log data”). Log data includes your IP address, browser type and settings, the date and time of your request, and how you interacted with the Website. Internet protocol (IP) addresses may be considered “personal data” in certain jurisdictions, such as in the European Economic Area (“EEA”), and will be treated in accordance with this Policy. 
• Cookies: Please see section 2 for further details:  
• ‍Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.  
  Usage Information: We collect information about how you use our Website, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities. 
  Domain Information: We may collect information regarding including the Website or other services you visited before and after interacting with the Website. 

‍Special Category Data: We may collect information concerning your health and sex life, if you give your explicit consent for us to do so. Such data will only be collected in the form of questions asked while interacting with the Website. If you choose to give your explicit consent for us to process your information, it will be stored securely with appropriate measures taken to protect your privacy. If you do not give your consent for us to process this data, we may collect this data in a fully anonymised manner unlinked to any personal identifying information.


In certain circumstances, providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Website, you may be unable to use those features. If you have created an account, you can contact us to ask us to update or correct your Personal Data.  


2. Cookies


We may use cookies to operate and administer our Website, gather usage data on our Website, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a Website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies).

The following sets out how we use different categories of cookies, as well as information on your options for managing the settings for the data collection by these technologies: 

Analytics/Performance: Used to recognise and count the number of Website visitors, to gather statistics regarding how visitors move around the Website (including number of page views, number of visitors, and time spent on each page) and for conversion tracking and click hotspots. This helps us improve the way our Website works and the user experience on it, for example by making sure users can find what they need easily. We use the following analytics/performance cookies: 

Google Analytics (provided by Google, Inc.):

• 
Type:

 Third-party persistent 
• 

Purpose:

The information generated by Google Analytics about your use of the Website (including your IP address) will be transmitted to and stored by Google, Inc. in the United States (pursuant to Google’s Privacy Shield certification). For more information on Google Analytics privacy practices, read here and, for information on Google Analytics cookies expiration, read here. You can opt out of the use of these cookies by using the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout?hl=en. 


• Expiry:

 Varies according to cookies used. For information on their expiration, read here.

Technical or strictly necessary cookies: Used to provide users with services available through the Website and to use some of its features, such as the ability to log-in and access secure areas and provide pop-up notices and accept language from sign up forms. These cookies are essential for using and navigating the Website. Without these cookies, basic functions of our Website would not work. Because these cookies are strictly necessary to deliver the Website and the services, users cannot refuse them.  


Cookies used to integrate third party services: Used to integrate third-party functionalities on the Website (such as videos, maps or social networks plug-ins). 

‍‍If you do not want to receive cookies from these third parties, you can also change your browser settings on your computer or other device you are using as described under the “Your Choices” section below. 

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Your Choices:

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On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please note that if you limit the ability of the Website to set cookies, you may be unable to access certain parts of the Website and you may not be able to benefit from the full functionality of the Website. 

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Advertising networks may use cookies to collect Personal Data. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there. If you access the Website on your mobile device, you may not be able to control tracking technologies through the settings.  


3. How we process Personal Data

Under Article 6 of the UK GDPR, we can only process personal data if we have a lawful basis for doing so, for example: (i) to comply with our legal and regulatory obligations; (ii) for the performance of our Terms of Use with you; (iii) for our legitimate interests or those of a third party; or (iv) where you have given consent, including for special category of personal data pursuant to Article 9 (2) (a) of the (UK) GDPR.

Legitimate interest may apply when we have, or a third party has, a business or commercial reason to process personal data, so long as this is not overridden by your own rights and interests. Whenever we process any personal data based on legitimate interest, we will conduct a Legitimate Interest Assessment to ensure that your interests do not override those legitimate interests of Mojo or of the third party, as applicable.

We use Personal Data for the following purposes: 

1. To process payments for the performance of our Terms of Use with you.
2. To respond to your inquiries, comments, feedback, or questions for the performance of our Terms of Use with you or to provide you with information you have requested.
3. To send administrative information to you, for example, information regarding the Website and changes to our terms, conditions, and policies for the performance of our Terms of Use with you.
4. To enable your participation in quizzes and online tests you chose to complete (not including marketing/promotional material). For the performance of our Terms of Use with you and/or based on your explicit consent for special category data, where applicable.
5. To analyze how you interact with our Website. For our legitimate interests or those of a third party, i.e. to be as efficient as we can in our delivery of the Website to you. We will rely on your explicit consent for special category data, where applicable.
6. To maintain and improve the content and functionality of the Website. For our legitimate interests or those of a third party, i.e. to enable us to improve our delivery of the Website to you.
7. To produce additional content and to administer and manage discussion forums. For our legitimate interests or those of a third party, i.e. to enable us to improve our delivery of the Website to you.
8. To prevent fraud, criminal activity, or misuse of our Website, and to ensure the security of our IT systems, architecture, and networks. For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations. 
9. To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties. To comply with our legal and regulatory obligations.
10. To tell you about content on the Website that we believe may be of interest to you and other direct marketing. For our legitimate interests or those of a third party, i.e. to promote our business to you, in line with the soft opt-in principle (see Marketing). 

Aggregated Information: We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Website, to improve and add features to our Website, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Website, make aggregated information available on our Website or use this for research or informational purposes, and we may share this aggregated information with our partners. We may collect aggregated information through the Website, through cookies, and through other means described in this Privacy Policy. 

Marketing: Mojo uses the ‘soft opt-in’ principle in relation to marketing messages on the lawful basis of our legitimate interests. If you have not opted out, we may use your Personal Data to contact you to tell you about relevant similar products or services we believe may be of interest to you. You may opt out of receiving emails by following the instructions when giving your details to Mojo or contained in each promotional email we send you. In addition, if at any time you do not wish to receive future marketing communications, you may contact us at support@mojo.so. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, as applicable, other administrative matters, and to respond to your requests. 

4. Sharing and Disclosure of Personal Data

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below: 

Vendors and Website Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors and web analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us.

Professional Service Providers: we may share Personal Data with professional advisers, including auditors and accountants, and those who provide consultancy, legal, financial, insurance and accounting services. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us.

Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Website, or the public, or (v) protect against legal liability. 

Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Data and other information may be shared in the diligence process with counter-parties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you. 

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. 

We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. 

5. Update your Information

If you have created an account, you can log in to your account or contact us if you need to change or correct your Personal Data.  

6. Children

Our Website is not directed to children who are under the age of 18. Mojo does not knowingly collect Personal Data from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Data to Mojo through the Website please contact us and we will endeavor to delete that information from our databases. 

7. Profiling and the use of Artificial Intelligence

We use an AI-powered chatbot to provide you with recommendations of activities to be done for the day. At each response, it will primarily consider our prompt (containing instructions and examples on how to respond, non-user-specific content), memories generated from your previous interactions (including previous recommendations, activities done), information provided by you during onboarding (including demographics, issues faced) and the Mojo content library in deciding how to respond. It will either give a text form response, or suggest Mojo content for the you to complete. If you encounter any issues while interacting with out chatbot, a "report" button will be available both on individual responses and the conversation as a whole. This will open an Intercom support message, so we can review and follow-up with you via our regular customer support processes. The chatbot's outputs, memory, etc. are all isolated per-user and you will be able to see and remove memories. We will only use the chatbot based on your consent. For more information, please see our Algorithmic Transparency Statement or contact us using the contact details provided below.

8. Third-party links

This Website may include links to third-party websites, plug-ins and applications. Please remember that when you use a link to go from our Website to another website or you request a service from a third party, this Policy no longer applies. Please be aware that we are not responsible or liable for the privacy practices of other websites. We encourage you to be aware when you leave the Website and to read the privacy policies of each and every website that collects personally identifiable information. This Policy applies solely to information collected by us on the Website. 

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Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.
 
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We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to personal data collected by us through our Website and does not apply to these third party websites and third party service providers.

9. Security


You use the Website at your own risk. We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

10. Additional information

Where your personal data is held: Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see section 4). Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see section ‘Transferring your personal data out of the EEA’ below. 

Transferring your personal data out of the EEA/UK: To deliver Website to you, it is sometimes necessary for us to share your personal data outside the EEA, for example our service providers located outside the EEA. These transfers are subject to special rules under European and UK data protection law. Some of these non-EEA countries may not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure. Our standard practice is to use standard data protection contract clauses which have been approved by the European Commission. If you would like further information please contact us at support@mojo.so. 

11. Your rights

You have the following rights, which you can exercise free of charge: 

Access: The right to be provided with a copy of your personal data and to obtain information about how we process your data.

Rectification: The right to require us to correct any mistakes in your personal data.
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To be forgotten: The right to require us to delete your personal data—in certain situations. Upon a valid data erasure request we will delete or anonymise your personal data unless an exception or an exemption applies. For example, we may need to keep some billing data as legally required for accounting purposes

Restriction of processing: The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data 

Data portability: The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations 

To object:  The right to object: (i) at any time to your personal data being processed for direct marketing (including profiling); and (ii) in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. 
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For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office. If you would like to exercise any of those rights, please contact us at our designated request address: support@mojo.so. 

How to complain:

We hope that we can resolve any query or concern you may raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint/ or telephone: 0303 123 1113. 

12. Data Retention


We will keep your personal data for as long as reasonably necessary for the purposes described in this Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer. To determine the appropriate retention period for your personal data, we will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Unless otherwise specified by legal requirements, we will retain personal data for the following periods:

• Special category (health, sex) data – 3 years after last user activity, after which data will be anonymised;
• Registration information, contact details, non-payment transactional data – 7 years after last user activity; and
• Payment records, customer support data – until no longer needed (maximum 15 years) or requested to be deleted.

13. Changes to the Privacy Policy


The Website and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Website or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you understand that you will be deemed to have agreed to be bound by the replacement Privacy Policy. 


14. Contact Us


If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: support@mojo.so. Alternatively, please contact our Data Protection Officer:

Aphaia Ltd

Eagle House

163 City Road,
London

EC1V 1NR

Telephone: +44 20 3917 4158
Email address: dpo@aphaia.co.uk

We have also designated a data protection representative in the EU. If you need to contact them, you can use the contact details below:

Data Protection Representative Europe, S.L
Paseo de la Castellana, 194
28046 Madrid, Spain
Email address: contact@dprep.eu