model.p

Privacy Policy

Last updated: 18 June 2026

This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use model.p by Mit ("the App"). We comply with the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018, and all applicable laws relating to privacy and data protection.

By creating an account or using the App, you acknowledge that you have read and understood this Privacy Policy.

1. Data Controller

The data controller responsible for your personal data is:

Ergalia Pty Ltd (a company incorporated in Australia, ACN 619 035 924, and registered as an overseas company in England and Wales under Companies House) London, United Kingdom mit@modelp-by-mit.com

2. Personal Data We Collect

2.1 Information You Provide:

Data collection and payment processing is handled by third‑party providers. We do not store full card details.

  • Name;
  • Email address;
  • Password (encrypted); and
  • Subscription information (plan type, renewal dates, payment confirmations).

Data collection and payment processing is handled by third‑party providers. We do not store full card details.

2.2 Automatically Collected Information (which may be collected by the app store or platform through which you access the App):

  • Device identifiers, operating system, and app version;
  • IP address and general location;
  • Usage analytics (e.g., which pages you view); and
  • Crash logs and performance diagnostics.

2.3 Optional Information

If you contact us, we may collect additional information you provide.

If you contact us, we may collect additional information you provide.

2.4 Cookies and Tracking Technologies

The App does not currently use cookies or similar tracking technologies. The app store or platform through which you download or access the App may use its own cookies or tracking technologies; such technologies are outside our control and are governed by the relevant platform's privacy policy. If we introduce analytics, cookies, or similar tracking technologies within the App in the future, we will update this Privacy Policy accordingly and, where required, obtain your consent in accordance with applicable law.

The App does not currently use cookies or similar tracking technologies. The app store or platform through which you download or access the App may use its own cookies or tracking technologies; such technologies are outside our control and are governed by the relevant platform's privacy policy. If we introduce analytics, cookies, or similar tracking technologies within the App in the future, we will update this Privacy Policy accordingly and, where required, obtain your consent in accordance with applicable law.

3. How We Use Your Personal Data

We process your personal data only where we have a lawful basis to do so under Article 6 of the UK GDPR. The lawful basis we rely on for each processing purpose is set out below.

3.1 To Provide the App and Subscription Services (lawful basis: contractual necessity — Article 6(1)(b) UK GDPR):

  • Creating and managing your account;
  • Providing access to subscription‑only investment information; and
  • Processing subscription payments.

3.2 To Improve and Secure the App (lawful basis: legitimate interests — Article 6(1)(f) UK GDPR, namely our interest in maintaining, improving, and securing the App):

  • Monitoring usage patterns;
  • Fixing bugs and improving performance; and
  • Preventing fraud and ensuring security.

3.3 To Communicate with You (lawful basis: contractual necessity — Article 6(1)(b) UK GDPR; or, where the communication is not necessary for the performance of the contract, legitimate interests — Article 6(1)(f) UK GDPR):

  • Service‑related notifications;
  • Subscription updates and renewal reminders; and
  • Responses to support requests.

3.4 To Comply with Legal Obligations (lawful basis: legal obligation — Article 6(1)(c) UK GDPR):

  • Responding to lawful requests from authorities; and
  • Maintaining records for tax and accounting.

4. Personalisation and Financial‑Promotion Controls

We may use your usage data to improve the App's functionality and content.

However:

  • We do not use your personal data to provide personalised investment recommendations;
  • We do not tailor investment content based on your financial circumstances; and
  • We do not use behavioural data to target financial promotions.

Any content you see is general, educational, and not based on your personal financial situation.

5. Sharing Your Personal Data

We may share your data with:

  • Hosting providers;
  • Analytics providers;
  • Payment processors;
  • Customer‑support tools;
  • Professional advisers (legal, accounting, compliance);
  • Regulators or law‑enforcement authorities where required; and
  • Successors in the event of a merger or acquisition.

We do NOT sell your personal data.

6. Data Retention

We retain your personal data only as long as necessary:

  • Account data retained while your account is active;
  • Subscription records retained for up to 6 years for tax and accounting; and
  • Technical logs retained for 12 months.

You may request deletion of your account at any time.

7. Your Rights

Under UK GDPR, you may request:

  • Access to your personal data;
  • Correction of inaccurate data;
  • Deletion of your data;
  • Restriction or objection to processing;
  • Withdrawal of consent (where applicable); and
  • Data portability.

Contact mit@modelp-by-mit.com to exercise your rights.

You also have the right to lodge a complaint with the Information Commissioner's Office ("ICO") if you consider that our processing of your personal data infringes applicable data protection law. The ICO can be contacted at ico.org.uk.

You also have the right to lodge a complaint with the Information Commissioner's Office ("ICO") if you consider that our processing of your personal data infringes applicable data protection law. The ICO can be contacted at ico.org.uk.

8. Security

We rely on third parties to implement appropriate technical and organisational measures, including:

  • Encryption of passwords;
  • Access controls;
  • Secure hosting environments; and
  • Regular security reviews.

No system is completely secure.

9. Children's Privacy

The App is not intended for individuals under 18.

We do not knowingly collect data from minors.

10. Changes to This Policy

We may update this Privacy Policy from time to time.

Material changes will be communicated through the App or by email.

11. Contact

For questions or concerns, contact:

mit@modelp-by-mit.com