PRIVACY POLICY

– Last updated 14 October 2026

1 About this policy

1.1 This policy explains what personal information we collect from you when you use our services or visit our website.

1.2 Minerva Private Ltd (“Minerva Cayman”, “Minerva”, “we”, “us”) is responsible for the personal information covered by this policy. We handle personal information in accordance with the Cayman Islands Data Protection Act.

2 Data collection

2.1 Minerva Private Ltd may collect personal information that we receive when you:

  • use our website
  • use our services
  • contact us

 

2.2 Depending on the services you request, we may collect:

  • Your name, contact details and identification information.
  • Information about your household, family, properties and personal or business affairs needed to provide our services.
  • Payment details, transaction records and information relating to funds held or payments made on your behalf.
  • Correspondence, instructions, service records and relevant photographs.
  • Information about other people involved in your requests, such as family members, household staff, authorised representatives and suppliers.
  • Sensitive personal information, such as health information, where necessary for an agreed service and permitted by applicable law.

 

2.3 We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including providing our services, meeting legal and accounting requirements, and resolving disputes. Retention periods depend on the type of information and the applicable requirements. When information is no longer needed, we securely delete or dispose of it, or anonymise it.

3 Website cookies

3.1 A ‘cookie’ is a small piece of information that is placed on your computer when you visit certain websites. When we refer to ‘cookies’ we include other technologies with similar purposes, such as tags and identifiers.

3.2 Our website provides cookie controls allowing you to accept or reject optional cookies and manage your preferences. Cookies necessary for the website to function remain enabled. Optional cookies, including analytics cookies, are used only with your consent. You can change your preferences through the website’s cookie settings.

3.3 The third-party cookies used on our website are mainly for understanding how the website performs, how you interact with our website, keeping our services secure and providing you with a better and improved user experience and helping speed up your future interactions with our website.

4 Why do we collect your information?

4.1 We use personal information to:

  • Respond to enquiries and set up and administer your Engagement.
  • Provide agreed services and carry out your instructions.
  • Coordinate with suppliers and other people involved in your requests.
  • Manage invoices, payments, retainers and accounting records.
  • Meet legal obligations and establish, exercise or defend legal claims.
  • Maintain the security and effective operation of our services and systems.
  • Send marketing communications where you have consented, subject to your right to opt out.

 

4.2 We process personal information where necessary to perform our agreement with you, comply with legal obligations or pursue legitimate business interests, provided those interests do not override your rights. Where consent is required, we will obtain it, and you may withdraw it at any time. Sensitive personal information is processed only where an applicable legal condition permits it.

5 How do we collect this information?

5.1 We collect personal information:

  • Directly from you when you contact us, use our website or instruct us to provide services.
  • From people authorised to act on your behalf.
  • From suppliers, professional advisers and other parties involved in providing your requested services.
  • From publicly available sources where relevant to our services.
  • Through correspondence and records created while carrying out your instructions.

 

5.2 We will always aim to keep your personal information as up to date as possible. However, if you believe we have made an error, please let us know and we will rectify it as soon as reasonably possible. You may ask us to correct or remove any inaccurate information.

6 Keeping your data safe

6.1 We use appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure. These include staff confidentiality obligations, access restricted according to responsibilities, approved business systems, and procedures for secure storage, handling and disposal of information.

6.2 Personal AI accounts are prohibited for company work. Employees may use only company-approved AI tools within our Microsoft business accounts, which offer enterprise data protection, including safeguards preventing prompts and responses from being used to train foundation models. Our employee policies prohibit submitting client documents, correspondence, images or any information that identifies, or could reasonably identify, a client to AI tools.

7 Third-party access

7.1 We may share personal information where reasonably necessary to provide our services, carry out your instructions, meet legal obligations or establish, exercise or defend legal claims. Recipients may include suppliers, contractors, professional advisers, public authorities and providers of technology, communications and payment services.

7.2 We limit the information shared to what is necessary for the relevant purpose. Where service providers process personal information on our behalf, we require appropriate confidentiality and data protection safeguards.

7.3 Our approved business technology providers may store or process personal information outside the Cayman Islands. The confidentiality and security measures described in section 6 apply regardless of where information is processed.

8 Marketing

8.1 If you have consented to receive marketing information, you can choose to opt out at any time by clicking ‘Unsubscribe’ on any MailChimp-generated email or emailing contact@minerva.ky.

9 Links to other websites

9.1 Our website might contain links to other websites of interest. Minerva Private Ltd does not have control over these websites, and so cannot be responsible for the protection/privacy of your personal information whilst visiting them.

10 Your rights and how to contact us

10.1 Under the Cayman Islands Data Protection Act, you have rights in relation to your personal information, including access, correction and, in certain circumstances, stopping or restricting its processing or requesting its deletion. You may also ask us to stop using your information for direct marketing.

10.2 To exercise your rights or ask a question about this policy, email contact@minerva.ky or write to Minerva Private Ltd, PO Box 2324, Grand Cayman KY1-1106, Cayman Islands. We may request information to verify your identity before responding.

10.3 If you have concerns about how we handle your personal information, please contact us so that we can investigate and respond.