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Contents
1. About this policy2. Who we are3. When we are a controller and when we are a processor4. Personal data we collect5. How we use personal data and our legal bases6. AI processing7. Who we share personal data with8. International transfers9. Cookies and similar technologies10. How long we keep personal data11. Security12. Your rights13. Children14. Third-party websites15. Changes to this policy

Privacy Policy

Mediacle Limited — MARS™

Version 2.2 — Last updated: 5 August 2026


1. About this policy

This policy explains how Mediacle Limited collects and uses personal data when you visit mars.mediacle.com, register for or use the MARS™ platform, correspond with us, or receive marketing from us.

If you are an affiliate, publisher or website owner and you have found this policy because your business contact details appear in MARS™, this is not the policy you need. Please read our Prospect Data Notice, which explains how we handle that data and how to have your details removed.


2. Who we are

Mediacle Limited is the controller of the personal data described in this policy.

CompanyMediacle Limited
Registered inEngland and Wales, company no. 08757407
Registered office16 Upper Woburn Place, London, WC1H 0BS, United Kingdom
VAT numberGB178524870
Emailmars@mediacle.com
Telephone+44 (0) 203 6088 364

EU Representative. For the purposes of Article 27 of the EU GDPR, our representative in the European Union is:

Chris K
Box no. 16416
103 27 Stockholm
Sweden

Individuals in the EEA may contact our EU Representative on any matter relating to our processing of their personal data under the EU GDPR.

We have not appointed a Data Protection Officer, as we are not required to do so. Privacy queries should be sent to mars@mediacle.com.


3. When we are a controller and when we are a processor

MARS™ is a business tool, and different data flows through it in different ways.

We are a controller — and this policy applies — for:

  • personal data about visitors to our website;
  • personal data about the individuals who register and use accounts on behalf of our business customers;
  • billing contacts and correspondence;
  • security, fraud prevention and audit logs;
  • our own marketing activity.

We are a controller under a separate notice for the business contact data held in the MARS™ affiliate directory. That processing is explained in our Prospect Data Notice.

We are a processor — and this policy does not govern that processing — for personal data our customers process inside their own MARS™ workspace, including outreach content, connected mailbox content, replies, pipeline records and campaign data. There, our customer decides what happens to the data and we act on its instructions under the Data Processing Agreement at Schedule 1 of our Terms of Service. If you have been contacted by a business using MARS™ and want to know why, that business is your first point of contact — though you can also use our removal form at https://mars.mediacle.com/data-removal and we will suppress you from our directory.


4. Personal data we collect

4.1 Data you give us

CategoryExamples
Identity and contactName, job title, business email address, telephone number, company name
AccountUsername, hashed password, account settings, brand and keyword configurations, team membership
BillingBilling name and address, VAT number, subscription and invoice history, partial card details (last four digits, card type, expiry) — full card details go directly to Stripe and are never received or stored by us
CorrespondenceEmails, support tickets, live chat, demo bookings, feedback, survey responses
MarketingPreferences, subscription status, engagement with our emails

4.2 Data we collect automatically

CategoryExamples
TechnicalIP address, browser type and version, operating system, device type, screen size, time zone, language
UsagePages viewed, features used, searches run, actions taken, timestamps, session duration, referring URL
SecurityLogin attempts, authentication events, API calls, error and audit logs
CookiesSee section 9

4.3 Data from third parties

  • Stripe — payment confirmations, subscription status, chargeback and fraud signals.
  • Analytics and advertising platforms — aggregated website analytics and advertising conversion data from our marketing website, where you have accepted those cookies on that site (see section 9.2). The MARS™ platform itself runs no analytics or advertising tags.
  • Publicly available sources — company information used to verify business customers and for business development.

4.4 Connected mailboxes

If you connect an email account to MARS™ using OAuth or SMTP, we access that mailbox only to send messages you compose or schedule, and to read replies and delivery signals relating to your MARS™ outreach so we can display them to you. We do not read, index or analyse unrelated correspondence, and we do not use mailbox content for advertising or for training AI models. You can disconnect a mailbox at any time in your account settings.


5. How we use personal data and our legal bases

What we doData usedLegal basis
Create and administer your account; provide MARS™Identity, contact, account, usageContract — necessary to perform our contract with you or your employer, or to take steps at your request before entering into one. Where you are an employee of our customer, legitimate interests in administering that contract
Take payment, invoice, chase non-paymentBilling, identityContract; legitimate interests in recovering sums due; legal obligation for tax records
Provide support and respond to enquiriesContact, correspondence, accountContract; legitimate interests in supporting our users
Secure the platform, detect and prevent fraud and abuseTechnical, security, usageLegitimate interests in protecting our service, our customers and third parties; legal obligation
Monitor, debug, analyse and improve MARS™Usage, technicalLegitimate interests in operating and improving a reliable product
Send service messages (outages, changes to terms, billing notices)Contact, accountContract; legal obligation
Send marketing about MARS™ and Mediacle productsContact, marketing preferencesConsent, or legitimate interests under the soft opt-in where you are an existing customer or enquirer. You can opt out at any time
Use your company name and logo to identify you as a customerCompany detailsContract — you grant this permission under clause 14.5 of our Terms; legitimate interests in promoting our business. Withdraw by emailing mars@mediacle.com
Website analytics and advertising on our marketing websiteCookie data, technicalConsent — via that site's cookie banner. Not used inside the MARS™ platform
Establish, exercise or defend legal claims; comply with law and regulatory requestsAny relevant dataLegal obligation; legitimate interests in protecting our legal position
Business transactions (sale, merger, restructuring)Any relevant dataLegitimate interests in operating and transacting our business

Where we rely on legitimate interests, we have assessed that our interests are not overridden by your interests and rights. You may request a summary of that assessment by emailing mars@mediacle.com.


6. AI processing

MARS™ uses artificial intelligence to generate drafts, summaries, scores and recommendations. Where this involves personal data, that data may be sent to our AI sub-processors (currently OpenAI and Anthropic) for processing.

  • We do not use customer data, account data or mailbox content to train, fine-tune or improve any AI model, and our AI sub-processors are contractually prohibited from doing so.
  • We may use aggregated and de-identified statistics to understand how the platform is used.
  • AI-generated output can be wrong. We do not make decisions producing legal or similarly significant effects about individuals by automated means without human involvement.

7. Who we share personal data with

RecipientPurpose
Amazon Web ServicesHosting, storage, compute, email delivery
StripePayment processing and fraud prevention
Hunter.ioBusiness contact discovery and email verification
OpenAI; AnthropicAI processing
Maxdesk.aiCustomer support ticketing
Google (Analytics)Website analytics, subject to consent
LinkedInAdvertising measurement, subject to consent
Professional advisersLawyers, accountants, auditors, insurers
AuthoritiesLaw enforcement, regulators and courts where legally required or necessary to protect our rights
AcquirersA buyer or prospective buyer of our business or assets, subject to confidentiality

An up-to-date sub-processor list is maintained at Schedule 2 of our Terms of Service.

We do not sell personal data. We do not share personal data with third parties for their own independent marketing purposes.


8. International transfers

Some of our providers are based outside the United Kingdom, principally in the United States, and the infrastructure on which MARS™ runs is global and may change.

Where we transfer personal data outside the UK to a country without UK adequacy regulations, we put in place one of the following:

  • the UK International Data Transfer Agreement (IDTA); or
  • the EU Standard Contractual Clauses together with the UK International Data Transfer Addendum,

supported by a transfer risk assessment and, where appropriate, additional technical measures such as encryption in transit and at rest.

You can request a copy of the relevant safeguard by emailing mars@mediacle.com.


9. Cookies and similar technologies

9.1 The MARS™ platform sets no cookies that require consent

Inside the platform at mars2.mediacle.net we set strictly necessary cookies only. These are permitted without consent by regulation 6(4) of the Privacy and Electronic Communications (EC Directive) Regulations 2003, which is why the platform shows you no cookie banner and asks you for no choice.

We do not run analytics, advertising, tracking or live-chat cookies inside the platform.

CookieSet byPurposeDuration
mars.sessionMediacle (mars2.mediacle.net)Keeps you signed in. Cannot be read by scripts (HttpOnly) and is not sent on cross-site requests24 hours, extended while you stay active
__stripe_mid, __stripe_sidStripePayment processing and fraud prevention. Set only on the checkout page, when you go to paySession to 12 months
Load balancing / infrastructureCloudflareRoutes traffic and protects the serviceSession to 12 months

Blocking these will stop parts of MARS™ working — signing in, in particular.

9.2 Our marketing website

mars.mediacle.com is a separate website, and it does use analytics and advertising cookies. Nothing in the table below loads until you accept that category on the banner shown on your first visit. Until you choose, Google Consent Mode is set to denied and neither tag runs.

CookieSet byPurposeDuration
_ga, _ga_<id>Google Analytics 4Counts visitors and sessions and shows which pages get read. Set only if you accept analytics cookiesUp to 2 years
bcookie, bscookie, lidc, li_sugr, li_gc, UserMatchHistory, AnalyticsSyncHistoryLinkedIn (Insight Tag)Measures which advertising brought you to the site. Set only if you accept advertising cookiesSession to 12 months
mars.cookie-consent (browser storage, not a cookie)MediacleRemembers your choice so we do not ask again. Strictly necessary, and kept even if you reject everything12 months

You can change or withdraw your choice at any time through Cookie Settings in the footer of that website. Withdrawing clears the cookies those tags set on mars.mediacle.com and reloads the page so they stop running — cookies held on linkedin.com can only be cleared by you or by LinkedIn. We ask again after 12 months. Third-party cookies are also governed by the provider's own privacy policy.

9.3 Other controls

Browser settings let you block or delete cookies at any time.


10. How long we keep personal data

DataRetention
Account and profile dataFor the life of the account, then 90 days after termination
Customer workspace data (as processor)90 days after termination, then deleted from active systems and purged from backups on the rolling backup cycle
Billing, invoicing and tax records7 years from the end of the relevant financial year (Companies Act 2006 and HMRC requirements)
Support correspondence3 years from last contact
Marketing preferences and opt-out recordsRetained indefinitely so we can honour your opt-out
Security, audit and access logsUp to 12 months
Website analyticsUp to 24 months, or the retention period configured in Google Analytics
Records relating to a legal claimUntil the claim is resolved and the applicable limitation period has expired

11. Security

We take security seriously and maintain measures including encryption of data in transit and at rest, role-based access controls on a least-privilege basis, individual named administrator accounts, multi-factor authentication for administrative access, hashed password storage, logical separation of customer workspaces, regular backups, and logging and monitoring. Our staff are bound by confidentiality obligations.

We do not currently hold ISO 27001, SOC 2 or Cyber Essentials certification, and we make no claim to be certified.

No system can be guaranteed secure. Transmission of data over the internet is at your own risk, and we cannot guarantee the security of data transmitted to our site.


12. Your rights

Under the UK GDPR and, where applicable, the EU GDPR, you have the right to:

  • Access a copy of the personal data we hold about you;
  • Rectify inaccurate or incomplete data;
  • Erase your data in certain circumstances;
  • Restrict our processing in certain circumstances;
  • Object to processing based on legitimate interests, and to object at any time to direct marketing, which we will always honour;
  • Portability — receive certain data in a structured, commonly used, machine-readable format;
  • Withdraw consent at any time where we rely on consent, without affecting processing carried out before withdrawal.

To exercise any right, email mars@mediacle.com. We will respond within one month, which we may extend by up to two further months for complex requests, in which case we will tell you. We may ask you to verify your identity. Exercising your rights is free, unless a request is manifestly unfounded or excessive.

Complaints. If you are unhappy with how we have handled your personal data, please tell us first so we can put it right. You also have the right to complain to the Information Commissioner's Office (ico.org.uk, 0303 123 1113, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF). If you are in the EEA, you may complain to your local supervisory authority or contact our EU Representative named in section 2.


13. Children

MARS™ is a business tool intended solely for use by adults acting in a business capacity. It is not directed at anyone under 18, and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, email mars@mediacle.com and we will delete it.


14. Third-party websites

Our website and the platform contain links to third-party sites, including affiliate websites identified through MARS™. We do not control those sites and are not responsible for their content, security or privacy practices. Their inclusion is not an endorsement.


15. Changes to this policy

We may update this policy. The current version is always at https://mars.mediacle.com/privacy with the date at the top. Where changes are material we will notify account holders by email or in-app before they take effect.


Mediacle Limited · Registered in England and Wales No. 08757407 · VAT No. GB178524870 16 Upper Woburn Place, London, WC1H 0BS, United Kingdom · mars@mediacle.com

This is the same document served inside the MARS™ platform. Questions: mars@mediacle.com

MARS
+44 (0) 203 6088 364mars@mediacle.comLive Chat — 24x7
Mediacle Limited
16 Upper Woburn Place, London,
WC1H 0BS United Kingdom
Registered in England and Wales, company no. 08757407
VAT no. GB178524870
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