Privacy Policy

Last updated: 16.07.2026

1. Introduction

This Privacy Policy explains how METROTEXT LIMITED ("METROTEXT", "we", "us" or "our") collects, uses, stores, shares, transfers and otherwise processes personal data when individuals access or use mitronex.com and the digital content, interactive features and related services made available through the Website (collectively, the "Service").

Mitronex operates as a digital entertainment service intended exclusively for recreational and entertainment purposes. The Service provides access to underwater-themed digital content, Digital Entertainment Experiences, Account functionality, Access Packages and related platform features.

M-Coins are internal digital interaction units used exclusively within the Service. They have no monetary, transferable or redeemable value and cannot be withdrawn, transferred, gifted, sold, exchanged or converted into money, cryptocurrency, goods, services or anything else with real or potential economic value.

This Privacy Policy applies to personal data processed in connection with browsing the Website, creating or using an Account, selecting an Access Package, receiving or using M-Coins, accessing Digital Entertainment Experiences, submitting a support request, communicating with METROTEXT LIMITED and otherwise interacting with the Service.

By accessing or using the Service, you acknowledge that your personal data will be processed as described in this Privacy Policy. Where processing requires consent under applicable law, we will request that consent separately and you may withdraw it in accordance with this Privacy Policy.

The Service is intended only for individuals aged eighteen or over. METROTEXT LIMITED does not knowingly permit persons under eighteen to register for or use the Service and does not knowingly collect their personal data.

This Privacy Policy should be read together with the Terms of Service, Fair Play Policy, M-Coins Policy and any other notices or policies published on the Website.

Capitalised terms not defined in this Privacy Policy have the meanings given to them in the Terms of Service.

2. Who We Are

METROTEXT LIMITED operates mitronex.com and acts as the controller of personal data processed through the Service, except where another organisation independently determines how and why it processes particular personal data.

METROTEXT LIMITED is a company incorporated in England and Wales under company number 16905638, with its registered office at International House, 101 King's Cross Road, London, England, WC1X 9LP.

As the controller, METROTEXT LIMITED determines the purposes and means of processing personal data and is responsible for handling that data in accordance with applicable data protection laws, including the UK General Data Protection Regulation, the Data Protection Act 2018 and, where applicable, the European Union General Data Protection Regulation.

Certain third parties, including Payment Providers, banks, card issuers and other independent service providers, may act as separate controllers for personal data processed for their own legal, regulatory, security or operational purposes. Their processing is governed by their own privacy policies and applicable legal obligations.

Privacy-related questions and requests may be submitted to support@mitronex.com.

METROTEXT LIMITED will use reasonable efforts to review and respond to privacy requests within the timeframes required by applicable law.

To protect personal data and prevent unauthorised access or disclosure, we may request information reasonably necessary to verify the identity and authority of a person submitting a privacy request before taking action.

3. Scope of This Privacy Policy

This Privacy Policy applies to personal data collected or otherwise processed by METROTEXT LIMITED through mitronex.com and the related Service.

It covers personal data processed when a User accesses or browses the Website, creates or maintains an Account, saves favourite experiences, selects an Access Package, receives or uses M-Coins, interacts with Digital Entertainment Experiences or other Service functionality, contacts customer support, submits a request or complaint, communicates with METROTEXT LIMITED or undergoes reasonable age, Account, payment, security or fraud-prevention checks.

This Privacy Policy applies to personal data collected directly from a User, generated automatically through the use of the Service or received from authorised third parties involved in payment processing, hosting, analytics, technical support, communications, security, fraud prevention or Service administration.

The Policy applies to processing carried out through the Website, supported mobile browser versions, Account interfaces, payment-related interactions, customer support channels, email communications, cookies, similar technologies and technical systems used to operate and protect the Service.

This Privacy Policy does not apply to third-party websites, applications or services that may be accessed through external links displayed on the Website. Such third parties process personal data under their own privacy policies, and METROTEXT LIMITED is not responsible for their independent privacy practices or content.

Where a third-party provider processes personal data on behalf of METROTEXT LIMITED, the processing will be subject to appropriate contractual arrangements and applicable data protection requirements.

Where a Payment Provider, bank, card issuer or other organisation processes personal data for its own purposes, it may act as an independent controller and will be separately responsible for that processing.

This Privacy Policy should be read together with the Terms of Service, Fair Play Policy and M-Coins Policy published on mitronex.com.

Where any provision of this Privacy Policy conflicts with a mandatory requirement of applicable data protection law, the mandatory legal requirement will prevail to the extent of that conflict.

4. Information We Collect

METROTEXT LIMITED may collect and process the categories of personal data described below in connection with the operation, administration, security and improvement of the Service.

4.1. Account and Registration Information

When you create or manage an Account, we may collect your first name, last name, email address, telephone number, password in encrypted or otherwise protected form, age confirmation, acceptance of the Terms of Service and Privacy Policy, Account settings and communication preferences.

We may also process information relating to Account status, registration date, password reset requests, verification status and changes made to Account details.

You must ensure that the information provided during registration remains accurate and current.

4.2. Payment and Transaction Information

Payments for Access Packages are processed by independent Payment Providers.

Full payment card details and security codes are submitted directly to and processed by the relevant Payment Provider. METROTEXT LIMITED may receive limited payment and transaction information required to confirm a payment, allocate an Access Package, provide customer support, process a refund, investigate a dispute or protect the Service against unauthorised activity.

This information may include the transaction reference, payment amount, currency, date and time, payment status, selected Access Package, Payment Provider, refund or chargeback status and limited or masked payment method details made available by the Payment Provider.

METROTEXT LIMITED does not use payment information to provide banking, payment account, electronic money or other financial services.

4.3. Technical and Device Information

When you access the Website, certain technical information may be collected automatically.

This may include your IP address, approximate location derived from the IP address, browser type and version, operating system, device type, device or session identifiers, language and time-zone settings, referral source, access date and time, technical logs, error records and information collected through cookies or similar technologies.

We may use this information to operate the Website, maintain security, diagnose technical issues, understand compatibility and prevent unauthorised or abusive activity.

4.4. Service Usage Information

We may collect information about how you interact with Mitronex and its functionality.

This may include login activity, Website navigation, Digital Entertainment Experiences accessed, interactions with platform features, saved favourite experiences, selected Access Packages, M-Coins allocations and usage, Account preferences, session duration, technical outcomes and other activity generated through use of the Service.

M-Coins activity is maintained as an internal platform record and does not represent financial account information, stored funds or monetary value.

4.5. Communications and Support Information

When you contact METROTEXT LIMITED, we may collect and retain the information contained in your communication.

This may include your name, email address, telephone number, Account details, transaction reference, the content of support requests, complaints or inquiries, attachments, correspondence history and information required to investigate or resolve the relevant matter.

Telephone or electronic communications may be documented where reasonably necessary for support, security, dispute resolution or record-keeping purposes.

4.6. Verification and Security Information

Where reasonably necessary to confirm eligibility, protect an Account, prevent fraud, investigate suspected misuse or comply with applicable legal or Payment Provider requirements, we may request or receive additional verification information.

This may include confirmation of age, identity or Account ownership, information about the payment method holder, location information and records relating to suspicious, unauthorised or disputed activity.

We will request only the information reasonably necessary for the relevant purpose and will not use verification information for unrelated purposes.

4.7. Information Received from Third Parties

We may receive limited personal data from third parties involved in operating or protecting the Service.

These parties may include Payment Providers, banks, card issuers, hosting providers, technical service providers, analytics providers, communications providers, fraud-prevention providers and professional advisers.

The information received may include payment status, transaction identifiers, technical or security signals, device or network information, refund and chargeback information, suspected unauthorised activity and other information necessary to provide, secure or administer the Service.

Third parties that process personal data for their own purposes may act as independent controllers and are responsible for providing information about their own processing.

4.8. Special Categories of Personal Data

METROTEXT LIMITED does not require Users to provide special categories of personal data, such as information concerning health, ethnicity, religion, political opinions, biometric data used for the purpose of uniquely identifying an individual, or sexual orientation, in order to use the Service.

Users should not submit such information unless it is strictly necessary for a specific legal, support or accessibility request.

Where special category personal data is incidentally provided, METROTEXT LIMITED will not use it unless an applicable Article 6 lawful basis and Article 9 condition have been identified. Information that is not necessary for the relevant request will be deleted or redacted where reasonably practicable.

4.9. Information Relating to Minors

The Service is available only to persons aged eighteen or over. METROTEXT LIMITED does not knowingly collect personal data from persons under eighteen.

If we reasonably believe that an Account or submitted personal data relates to a person under eighteen, we may request verification, restrict access and delete the relevant information where appropriate, subject to legal and record-retention obligations.

4.10. Information Required to Use the Service

Certain personal data is required to create and secure an Account, confirm eligibility, select an Access Package or respond to a User's request. Mandatory fields will be identified at the point of collection.

If required registration information is not provided, the User may be unable to create an Account or access registered Service features. If information required for payment processing is not provided, the relevant Payment Provider may be unable to process the payment or make the selected Access Package available.

Information relating to optional Cookies, marketing preferences and other optional functionality is not required to create an Account or access the core Service, unless otherwise clearly explained at the point of collection.

5. How We Use Personal Data

METROTEXT LIMITED processes personal data only for specified and legitimate purposes and where the processing is supported by an appropriate legal basis under applicable data protection law.

5.1. Providing and Administering the Service

We may process personal data to register and maintain Accounts, authenticate Users, provide access to Mitronex, save favourite experiences, administer Account preferences and make Digital Entertainment Experiences and related functionality available.

We may also use personal data to allocate and record M-Coins, maintain internal Service records and provide the features included in an Access Package.

5.2. Processing Access Packages and Payments

We may process limited transaction information to present available Access Packages, confirm payment status, allocate the relevant package and M-Coins, maintain transaction records and provide payment-related support.

We may also use transaction information to process refunds, investigate duplicate or disputed payments, respond to chargebacks and reconcile information received from Payment Providers.

Full payment card details are processed by the relevant Payment Provider and are not required by METROTEXT LIMITED for the ordinary administration of an Access Package.

5.3. Account and Customer Support

We may use personal data to respond to questions, resolve technical issues, assist with Account access, investigate complaints, process privacy requests and provide information concerning M-Coins, Access Packages, payments or the operation of the Service.

We may retain relevant correspondence to maintain an accurate support history, demonstrate how a request was handled and improve the consistency of future support.

5.4. Security and Fraud Prevention

We may process personal data to authenticate Accounts, identify unusual or unauthorised activity, protect login credentials, prevent misuse of payment methods, investigate suspected fraud, detect prohibited conduct and maintain the security and integrity of the Service.

This may include comparing Account, device, network, transaction and usage information where reasonably necessary to identify technical manipulation, duplicate Accounts, unauthorised access or abuse of refunds and chargebacks.

Where appropriate, we may temporarily restrict an Account or payment functionality while an issue is reviewed.

5.5. Eligibility and Verification

We may use personal data to confirm that a User satisfies the age and eligibility requirements set out in the Terms of Service.

Where reasonably necessary, we may verify age, identity, Account ownership, location or authority to use a payment method. Verification may also be carried out in response to a security incident, disputed transaction or request to recover an Account.

5.6. Legal and Compliance Purposes

We may process personal data to comply with applicable laws, court orders and lawful requests from public authorities.

We may also use personal data to maintain legally required records, enforce the Terms of Service and other platform policies, establish, exercise or defend legal claims and protect the rights, property and legitimate interests of METROTEXT LIMITED, Users, Payment Providers and other persons.

5.7. Service Operation, Maintenance and Improvement

We may process technical and usage information to monitor Website performance, diagnose errors, maintain compatibility, conduct testing, improve security and develop or refine Service functionality.

We may analyse how Users navigate the Website, interact with Digital Entertainment Experiences and use Account features in order to understand general usage patterns and improve the Service.

Where reasonably practicable, internal reporting and analysis will use aggregated, anonymised or de-identified information.

5.8. Service Communications

We may use contact information to send messages necessary for the operation of the Service.

These communications may include registration confirmations, password reset instructions, Account security alerts, payment confirmations, support responses, policy updates, material changes to the Service and other administrative notices.

Service communications are not promotional messages and may be necessary for the performance, security or administration of the User's Account.

We will send marketing or promotional communications only where such communications are introduced through the Service, are permitted by applicable law and any required consent or opt-out mechanism has been provided.

5.9. Corporate and Business Transactions

Personal data may be processed or disclosed where reasonably necessary in connection with a proposed or completed merger, acquisition, restructuring, financing, sale of assets or transfer of all or part of METROTEXT LIMITED's business.

Any recipient will be required to protect the information through appropriate confidentiality, security and data protection arrangements.

Users will be informed where required by applicable law and where a change affects the identity of the controller or the manner in which personal data is processed.

5.10. Automated Processing

METROTEXT LIMITED may use automated tools to support security monitoring, fraud detection, technical analysis and the identification of unusual activity.

METROTEXT LIMITED does not currently make decisions based solely on automated processing that produce legal or similarly significant effects for Users.

Where applicable law requires it, Users will be informed about qualifying automated decision-making and any available right to request human review, express their views or challenge the decision.

6. Legal Bases for Processing Personal Data

METROTEXT LIMITED processes personal data only where an appropriate lawful basis applies under the UK GDPR, the Data Protection Act 2018 and, where relevant, the EU GDPR.

The applicable lawful basis depends on the purpose of the processing and the circumstances in which the personal data is collected. More than one lawful basis may apply to different processing activities involving the same category of personal data. METROTEXT LIMITED identifies and documents the relevant basis before processing personal data for a particular purpose.

6.1. Performance of a Contract

We may process personal data where it is necessary to perform the Terms of Service entered into with a User or to take steps requested by the User before entering into that agreement.

This may include processing personal data to create and administer an Account, authenticate the User, provide access to the Service, maintain Account functionality, save favourite experiences, process the selection of an Access Package, confirm payment status, allocate M-Coins, provide Digital Entertainment Experiences and respond to requests concerning the User's Account or purchased digital content.

We rely on this basis only where the processing is objectively necessary to provide the relevant contractual service. Processing that is merely useful or convenient but not necessary for the contract will be supported by another appropriate lawful basis.

6.2. Compliance with Legal Obligations

We may process personal data where necessary to comply with a legal obligation applicable to METROTEXT LIMITED.

This may include maintaining records required by law, responding to binding court orders or lawful requests from competent authorities, meeting tax and accounting requirements, handling statutory consumer or data protection requests and complying with obligations relating to fraud prevention, security or unlawful activity.

Where a request is made by a public authority, we will assess its legal basis and disclose only the personal data that we are legally required or permitted to provide.

6.3. Legitimate Interests

We may process personal data where the processing is necessary for a legitimate interest pursued by METROTEXT LIMITED or a third party and that interest is not overridden by the User's interests, rights or freedoms.

Our legitimate interests may include operating and administering the Service, maintaining Website and Account security, preventing fraud and unauthorised activity, investigating misuse, protecting Payment Providers and Users, enforcing the Terms of Service and related policies, maintaining internal records, improving technical performance, understanding general Service usage, responding to disputes and establishing, exercising or defending legal claims.

Before relying on legitimate interests, we consider the purpose of the processing, whether the processing is necessary and whether the User's rights and reasonable expectations outweigh the identified interest. Additional safeguards may be applied where the processing could create a greater impact on the User.

6.4. Consent

We may process personal data on the basis of consent where consent is required or is the most appropriate lawful basis.

This may apply to optional cookies and similar technologies, optional marketing communications or another clearly identified processing activity that is not necessary to provide the Service.

Consent will be requested through a clear affirmative action and will not be treated as given merely because a User accesses the Website.

Where processing is based on consent, the User may withdraw that consent at any time through the relevant preference mechanism or by contacting support@mitronex.com. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

6.5. Legal Claims and Dispute Resolution

Personal data may be processed where reasonably necessary to investigate a complaint, respond to a payment dispute, manage a chargeback, enforce an agreement or establish, exercise or defend a legal claim.

Depending on the circumstances, such processing may rely on legitimate interests, compliance with a legal obligation or another basis permitted by applicable law.

Where special category personal data is relevant to a legal claim, METROTEXT LIMITED will identify both an Article 6 lawful basis and an applicable additional condition for processing that information.

6.6. Security and Fraud Prevention

Depending on the circumstances, related processing may be necessary for the performance of the Terms of Service, compliance with legal obligations or the legitimate interests of METROTEXT LIMITED, Users, Payment Providers and other affected parties.

We may process Account, technical, device, usage and limited transaction information to identify unauthorised access, payment misuse, duplicate Accounts, technical manipulation, fraudulent refund requests, chargeback abuse and other prohibited conduct.

Such processing will be limited to what is reasonably necessary and proportionate to the identified security or fraud risk.

Criminal Offence Data

Where fraud-prevention or security activities involve personal data relating to suspected or alleged unlawful conduct, METROTEXT LIMITED will process such information only where an applicable lawful basis and an additional condition required by the Data Protection Act 2018 have been identified. Such processing will be limited to what is necessary and proportionate for the relevant purpose.

6.7. Data Protection Principles

Regardless of the lawful basis relied upon, METROTEXT LIMITED processes personal data in accordance with the principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity and confidentiality.

Personal data will not be used for a materially incompatible purpose unless that further processing is permitted by applicable law and the User is provided with any information or choice required in the circumstances.

7. Sharing and Disclosure of Personal Data

METROTEXT LIMITED does not sell personal data.

We may share personal data only where there is an appropriate lawful basis and the disclosure is reasonably necessary to operate, support or protect the Service, fulfil an agreement with a User, comply with law or manage a legitimate business requirement.

7.1. Service Providers Acting on Our Behalf

We may engage service providers to process personal data on behalf of METROTEXT LIMITED.

These providers may support website hosting, cloud infrastructure, data storage, technical maintenance, cybersecurity, communications, email delivery, customer support, analytics, error monitoring, fraud prevention and other functions necessary to operate the Service.

Service providers acting as processors may use personal data only for the agreed purposes, on documented instructions and subject to appropriate confidentiality, security and data protection obligations.

Where required by applicable law, METROTEXT LIMITED enters into written data processing arrangements with processors and assesses whether they provide sufficient guarantees for the protection of personal data.

7.2. Payment Providers and Financial Institutions

Personal data and limited transaction information may be shared with or received from Payment Providers, banks, card issuers and other participants involved in processing, authorising, reversing or investigating a payment.

This may be necessary to confirm payment status, allocate an Access Package, issue a refund, investigate an unauthorised transaction, manage a chargeback, prevent fraud or provide payment-related support.

Payment Providers, banks and card issuers may determine independently how and why they process personal data for payment authorisation, fraud prevention, legal compliance and dispute management. Where they act as independent controllers, their processing is governed by their own privacy notices.

METROTEXT LIMITED does not receive complete payment card security codes and does not require full payment card credentials to administer the Service.

7.3. Professional Advisers and Business Support

We may disclose personal data where reasonably necessary to professional advisers and business support providers, including legal advisers, accountants, auditors, insurers, consultants and information security specialists.

These recipients are required to maintain confidentiality and may use personal data only for the professional or support purpose for which it was disclosed.

7.4. Legal and Regulatory Disclosures

We may disclose personal data where required by applicable law, a binding court order or a valid request from a competent governmental, regulatory or law enforcement authority.

Personal data may also be disclosed where reasonably necessary to protect the rights, safety or security of METROTEXT LIMITED, a User, a Payment Provider or another person; investigate suspected fraud or unlawful activity; enforce the Terms of Service or related policies; or establish, exercise or defend legal claims.

We will assess the scope and legal basis of a request and, where legally permitted, limit the disclosure to the information reasonably necessary for the relevant purpose.

7.5. Corporate Transactions

Personal data may be disclosed to prospective or actual purchasers, investors, lenders, advisers or other participants in connection with a proposed or completed merger, acquisition, financing, restructuring, sale of assets or transfer of all or part of METROTEXT LIMITED's business.

Before completion of a transaction, disclosures will be limited to what is reasonably necessary and will be subject to appropriate confidentiality and data protection arrangements.

Where the identity of the controller changes, Users will be informed where required by applicable law.

7.6. Aggregated and Anonymised Information

We may use or disclose aggregated or anonymised information that does not identify a User and cannot reasonably be used to identify them.

Information that remains capable of being linked to an identifiable person will continue to be treated as personal data and protected under this Privacy Policy.

7.7. Protection of Shared Personal Data

METROTEXT LIMITED applies reasonable due diligence when selecting service providers and requires appropriate contractual, organisational and security safeguards where the recipient processes personal data on our behalf.

The level of protection and the contractual arrangement applied will depend on the recipient's role, the nature of the personal data, the processing purpose and the legal requirements applicable to the disclosure.

8. International Data Transfers

METROTEXT LIMITED is established in the United Kingdom, but some service providers used to operate the Service may process or access personal data from countries outside the United Kingdom or the European Economic Area.

An international transfer may occur where personal data is stored in another country, accessed remotely from another jurisdiction or disclosed to a recipient located outside the jurisdiction in which the data was originally collected.

Where a transfer is subject to the international transfer restrictions of the UK GDPR or EU GDPR, METROTEXT LIMITED will use a legally recognised transfer mechanism and apply appropriate safeguards.

For transfers governed by UK data protection law, this may include UK adequacy regulations, the United Kingdom International Data Transfer Agreement, the UK Addendum to approved EU Standard Contractual Clauses or another safeguard or exception permitted by law. The UK IDTA and Addendum impose contractual protections intended to maintain an appropriate level of protection when personal data is transferred outside the United Kingdom.

For transfers governed by the EU GDPR, safeguards may include an adequacy decision adopted by the European Commission, the European Commission's Standard Contractual Clauses, binding corporate rules or another lawful transfer mechanism.

Where required, we will assess the circumstances of the transfer and whether the laws and practices of the destination country could affect the protection provided by the relevant safeguard. Supplementary technical, contractual or organisational measures may be implemented where reasonably necessary.

International service providers may include hosting, cloud infrastructure, technical support, communications, analytics, cybersecurity, fraud-prevention and Payment Providers. The use of a global provider does not automatically mean that personal data is transferred to every country in which that provider operates.

METROTEXT LIMITED will not make a restricted international transfer unless an appropriate legal mechanism, safeguard or permitted exception applies.

Users may request further information about the categories of recipients, destination countries and safeguards relevant to their personal data by contacting support@mitronex.com. Where appropriate, we may provide a summary or redacted copy of the relevant safeguard, subject to confidentiality and security restrictions.

9. Data Retention

METROTEXT LIMITED retains personal data only for as long as reasonably necessary to provide and administer the Service, fulfil the purposes described in this Privacy Policy, comply with applicable legal obligations, resolve disputes and protect the security and integrity of Mitronex.

Retention periods depend on the category of personal data, the purpose for which it is processed, the nature of the User's relationship with METROTEXT LIMITED and any applicable legal, accounting, tax, security or dispute-resolution requirements.

We maintain internal retention procedures and periodically review the personal data we hold to determine whether it remains necessary for the relevant processing purpose.

9.1. Account Information

Account and registration information may be retained while an Account remains active and for a reasonable period after closure, suspension or termination.

Following Account closure, we may retain limited information where necessary to confirm that the Account was closed, respond to subsequent inquiries, prevent duplicate or unauthorised Accounts, investigate misuse, resolve disputes or comply with legal obligations.

Information that is no longer required for these purposes will be deleted, anonymised or securely disposed of.

9.2. Payment and Transaction Information

Payments are processed by independent Payment Providers. METROTEXT LIMITED does not retain complete payment card numbers or payment card security codes.

Limited transaction information received from Payment Providers may be retained for as long as necessary to confirm Access Package payments, administer M-Coins allocations, process refunds, respond to payment inquiries, manage disputes or chargebacks and satisfy applicable accounting, tax and legal requirements.

Payment Providers, banks and card issuers determine their own retention periods for personal data processed independently by them.

9.3. M-Coins and Service Usage Records

Records relating to M-Coins allocations, usage, deductions, adjustments and corrections may be retained while the Account is active and for a reasonable period thereafter.

Such records may be required to maintain Account accuracy, investigate technical errors, respond to User inquiries, verify refunds or payment reversals, identify misuse and demonstrate how an Account or Access Package was administered.

Service usage information and saved preferences may be deleted or anonymised when they are no longer required for Account administration, analytics, security or legal purposes.

9.4. Communications and Support Records

Support requests, complaints, inquiries and related correspondence may be retained for as long as reasonably necessary to respond to the User, maintain an accurate support history, investigate the relevant issue, improve customer support and establish, exercise or defend legal claims.

Where communications concern a payment dispute, Account restriction, fraud investigation or legal complaint, they may be retained for a longer period where reasonably necessary for the resolution of that matter.

9.5. Technical and Security Information

Technical logs, device information, login records, network information and security records may be retained for periods reasonably necessary to operate and protect the Service, diagnose errors, investigate incidents and prevent fraud or unauthorised access.

Security records may be retained after Account closure where reasonably necessary to prevent repeated misuse, maintain evidence of a security incident or protect METROTEXT LIMITED, Users and Payment Providers.

9.6. Verification Information

Information collected to verify age, identity, Account ownership, location or authority to use a payment method will be retained only for as long as necessary for the relevant verification, security, dispute-resolution or legal purpose.

Where it is not necessary to retain a full copy of a verification document, METROTEXT LIMITED may retain only the verification result, date, reference or other limited information required to demonstrate that the relevant check was completed.

9.7. Account Closure, Suspension and Termination

Closing an Account does not necessarily result in the immediate deletion of all personal data.

Following closure, suspension or termination, we may retain information where necessary to comply with legal obligations, resolve outstanding payments or complaints, investigate prohibited conduct, prevent fraud, enforce the Terms of Service or establish, exercise or defend legal claims.

Information retained for these purposes will not be used to provide active Account functionality or for unrelated purposes.

9.8. Backups and Technical Archives

Personal data may remain temporarily within secure backups or technical archives after it has been removed from active systems.

Backup copies are protected against ordinary access and will be deleted or overwritten in accordance with the applicable backup cycle, unless continued retention is required for security, disaster recovery or legal purposes.

9.9. Deletion and Anonymisation

When personal data is no longer required and no lawful basis exists for continued retention, METROTEXT LIMITED will delete, anonymise or securely dispose of it.

Where information is irreversibly anonymised so that it can no longer be linked to an identifiable individual, it may be retained and used for statistical, analytical or operational purposes without being treated as personal data.

9.10. Extended Retention

Personal data may be retained for longer where required by applicable law, a binding court order, a lawful request from a competent authority or the existence of an actual or reasonably anticipated complaint, investigation, dispute or legal claim.

Where extended retention is necessary, access to the relevant information may be restricted to persons who require it for the specific retention purpose.

10. Your Privacy Rights

Depending on your location, the applicable data protection law and the circumstances of the processing, you may have some or all of the rights described below.

These rights are not absolute and may be subject to legal conditions, limitations or exemptions. METROTEXT LIMITED will assess each request in accordance with the law applicable to the relevant processing.

10.1. Right of Access

You may request confirmation as to whether METROTEXT LIMITED processes your personal data.

Where applicable, you may request a copy of that personal data together with information about the purposes of processing, the categories of data involved, the recipients or categories of recipients, the applicable retention criteria and the source of the information where it was not collected directly from you.

10.2. Right to Rectification

You may request correction of inaccurate personal data or completion of information that is incomplete.

You may be able to update certain Account information directly through the Service. Where direct correction is unavailable, you may contact METROTEXT LIMITED for assistance.

10.3. Right to Erasure

You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, consent has been withdrawn and no other lawful basis applies, a valid objection has been made, the information has been processed unlawfully or deletion is otherwise required by law.

The right to erasure is not absolute. We may retain personal data where processing remains necessary to comply with a legal obligation, exercise freedom of expression, perform a task in the public interest, establish, exercise or defend legal claims or satisfy another lawful exception.

Closing an Account does not automatically require the deletion of information that METROTEXT LIMITED must lawfully retain.

10.4. Right to Restriction of Processing

You may request that processing of your personal data be restricted where you contest its accuracy, believe that the processing is unlawful but do not want the data deleted, require the data for a legal claim after it is no longer required by METROTEXT LIMITED, or have objected to processing while the objection is being assessed.

While processing is restricted, the relevant personal data will generally be stored but will not otherwise be used except with your consent, for legal claims, to protect another person's rights or for another purpose permitted by law.

10.5. Right to Data Portability

Where processing is based on consent or contractual necessity and is carried out by automated means, you may request certain personal data that you provided to METROTEXT LIMITED in a structured, commonly used and machine-readable format.

Where technically feasible and legally applicable, you may also request that the information be transmitted directly to another controller.

This right does not generally apply to derived, inferred or anonymised information created by METROTEXT LIMITED.

10.6. Right to Object

You may object to processing based on legitimate interests where your particular circumstances justify the objection.

Where a valid objection is made, METROTEXT LIMITED will stop the relevant processing unless compelling legitimate grounds exist that override your interests, rights and freedoms, or the processing is required to establish, exercise or defend legal claims.

An objection does not automatically require the deletion of an Account or all information associated with it.

You have the right to object at any time to processing based on legitimate interests where your particular circumstances justify the objection. You also have an unconditional right to object to the use of your personal data for direct marketing.

10.7. Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time through the relevant preference mechanism or by contacting support@mitronex.com.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Where the relevant processing is necessary to provide an optional feature, withdrawing consent may result in that feature becoming unavailable.

10.8. Direct Marketing

You may object to direct marketing or unsubscribe from marketing communications at any time by using the unsubscribe mechanism included in the relevant message or by contacting METROTEXT LIMITED.

Once an objection has been received, your personal data will no longer be used for direct marketing through the affected communication channel.

You may continue to receive non-promotional communications required for Account administration, security, Access Package confirmation, support, policy updates or the operation of the Service.

10.9. Automated Decision-Making

Where applicable law provides such a right, you may request not to be subject to a decision based solely on automated processing that produces legal effects or similarly significantly affects you.

METROTEXT LIMITED does not intend to make such decisions without an appropriate lawful basis and the safeguards required by applicable law.

Where qualifying automated decision-making is used, you may have the right to obtain human intervention, express your point of view and challenge the decision.

10.10. Exercising Your Rights

Privacy rights requests may be submitted to support@mitronex.com.

Your request should clearly identify the right you wish to exercise and provide sufficient information to locate the relevant personal data.

To protect Accounts and personal data against unauthorised disclosure, METROTEXT LIMITED may request reasonable information to verify your identity and authority before completing the request.

Where a request is submitted by an authorised representative, we may require evidence of that person's authority to act on your behalf.

10.11. Response Timeframes

METROTEXT LIMITED will respond to a valid privacy rights request without undue delay and normally within one month after receiving the request and any information reasonably required to verify the requester's identity.

Where a request is complex or multiple requests have been submitted, the response period may be extended by up to two additional months where permitted by law. We will inform you of the extension and the reasons for it within the initial response period.

Privacy rights requests will ordinarily be handled free of charge. Where a request is manifestly unfounded or excessive, particularly because it is repetitive, METROTEXT LIMITED may charge a reasonable administrative fee or refuse to act where permitted by applicable law.

Where we refuse a request in whole or in part, we will explain the reason and provide information about any available right to complain to a supervisory authority or seek a judicial remedy.

11. Complaints

METROTEXT LIMITED is committed to reviewing complaints fairly, appropriately and without undue delay.

Complaints concerning the Service, an Account, Access Packages, M-Coins, payments, refunds, personal data, customer support or any other aspect of Mitronex may be submitted to support@mitronex.com or through the support form available on mitronex.com.

A complaint should contain sufficient information to allow METROTEXT LIMITED to identify the relevant User, Account, transaction or processing activity and understand the nature of the issue.

Where the complaint concerns a payment, the User should provide the Account email address, transaction reference, payment date and a clear description of the matter.

METROTEXT LIMITED may request additional information where reasonably necessary to verify the complainant's identity or authority, investigate the circumstances or resolve the complaint. Any requested information will be limited to what is reasonably necessary for the relevant purpose.

METROTEXT LIMITED will normally acknowledge receipt of a complaint within seven business days. A complaint concerning the processing of personal data will be acknowledged no later than thirty days after receipt.

METROTEXT LIMITED will take appropriate steps to investigate the complaint without undue delay, make reasonable enquiries into the circumstances and keep the complainant informed of material progress or any expected delay.

For complaints that do not primarily concern personal data, METROTEXT LIMITED will normally aim to provide a substantive response within thirty days. Where a complaint is complex, involves a Payment Provider or another third party, or requires additional investigation, the review may take longer. In such circumstances, the User will be informed that additional time is required and, where reasonably possible, will receive an indication of the expected response period.

Once the review of a complaint concerning personal data has been completed, METROTEXT LIMITED will communicate the outcome and any action taken or proposed without undue delay.

Users are encouraged to contact METROTEXT LIMITED first so that the matter can be reviewed and, where possible, resolved directly. This does not restrict any right to contact the Information Commissioner's Office, another competent supervisory authority, a consumer protection body, a Payment Provider, a court or another competent organisation.

Nothing in this section limits any mandatory right or remedy available under applicable law.

12. Cookies and Similar Technologies

Mitronex may use cookies, local storage, pixels and similar technologies collectively referred to as "Cookies" to operate, secure, maintain and improve the Website.

Cookies may be placed directly by METROTEXT LIMITED or by authorised third-party providers supporting the operation, security, analytics or functionality of the Service.

12.1. What Cookies Are

Cookies are small files or similar technical identifiers stored on or accessed from a User's device when the Website is visited or used.

Cookies may process information relating to a browser, device, session, Website activity, preferences and interactions with Service functionality.

Some Cookies remain only for the duration of the browser session, while others may remain on the device for a defined period or until deleted.

12.2. Strictly Necessary Cookies

Strictly necessary Cookies are required to provide functions requested by the User or to maintain the security and proper operation of the Website.

They may be used to maintain sessions, authenticate Accounts, remember essential privacy choices, support checkout functionality, protect forms, prevent unauthorised access and maintain Website security.

These Cookies cannot normally be disabled through the Website's consent settings because the Service may not function correctly without them.

12.3. Functional Cookies

Functional Cookies may be used to remember optional settings and improve how the Website operates for a returning User.

They may remember language, interface, accessibility or other preferences selected by the User.

Disabling functional Cookies may cause certain preferences or non-essential features to become unavailable or require repeated selection.

12.4. Analytics and Performance Cookies

Where used, analytics and performance Cookies help METROTEXT LIMITED understand how Users interact with the Website.

They may provide information about page visits, navigation paths, session duration, technical errors, device compatibility and general usage patterns.

Information collected through these technologies may be used to measure Website performance, diagnose technical issues and improve the design and functionality of Mitronex.

Where required by applicable law, analytics and performance Cookies will be activated only after the User has provided consent.

12.5. Security and Fraud-Prevention Technologies

Cookies and similar technical identifiers may be used to protect Accounts, payments and the Service against unauthorised access, technical manipulation, fraud and other prohibited activity.

These technologies may support session security, identify unusual access patterns, detect automated requests and assist with the investigation of security incidents.

Where a security technology is strictly necessary for the provision or protection of the Service, it may be used without consent to the extent permitted by applicable law.

12.6. Marketing Cookies

METROTEXT LIMITED will use marketing or advertising Cookies only if such functionality is introduced through the Website and is permitted by applicable law.

Where used, these Cookies may help measure the effectiveness of communications or campaigns and understand whether a User interacted with relevant promotional content.

Marketing Cookies will not be activated before any consent required by applicable law has been obtained.

Users may withdraw or change their consent through the available cookie preference tool.

12.7. Third-Party Cookies

Certain Cookies may be placed or accessed by third-party providers supporting Website hosting, payment processing, analytics, security, communications or other Service functionality.

Where a third party determines independently how and why information collected through its Cookies is processed, that party may act as a separate controller and its processing will be governed by its own privacy notice.

The availability of a third-party feature on the Website does not permit the provider to use personal data for unrelated purposes on behalf of METROTEXT LIMITED.

12.8. Cookie Preferences

Where required, Mitronex will display a cookie notice or preference tool allowing Users to accept, reject or manage non-essential Cookies.

Users may change their preferences at any time through the cookie settings made available on the Website.

Cookies may also be blocked or deleted through browser or device settings. Browser controls vary, and Users should consult the instructions provided by the relevant browser or device provider.

Blocking strictly necessary Cookies may prevent the Website, Account functionality or payment-related features from operating correctly.

12.9. Legal Basis

Strictly necessary Cookies may be used without consent where they are required to provide a service requested by the User, transmit a communication or maintain essential security and functionality.

Non-essential Cookies, including optional analytics, functionality or marketing Cookies, will be used on the basis of consent where required by applicable law.

Personal data subsequently processed through Cookies may also be handled under another lawful basis described in this Privacy Policy where appropriate.

12.10. Updates and Further Information

The Cookies and similar technologies used by Mitronex may change as the Website, Service providers and technical functionality are updated.

Where a material change affects the use of Cookies or the choices available to Users, METROTEXT LIMITED will update the relevant notice or preference mechanism.

Further details about specific Cookies, their providers, purposes and duration may be provided through a separate Cookies Policy or cookie management tool available on mitronex.com.

13. Security of Personal Data

METROTEXT LIMITED implements appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, access, misuse or other unlawful processing.

The measures applied depend on the nature and volume of the personal data processed, the purposes of the processing, the available technology and the likelihood and severity of potential risks to Users.

13.1. Security Measures

Security measures may include access controls, authentication procedures, password protection, encryption or pseudonymisation where appropriate, network and infrastructure safeguards, system monitoring, technical logging, vulnerability management, secure backup procedures and incident response processes.

METROTEXT LIMITED may also use measures designed to detect unauthorised access, fraudulent payments, Account compromise, technical manipulation and other activity that may threaten the security or integrity of the Service.

Security controls are reviewed and updated where reasonably necessary to address changes in technology, processing activities and identified risks.

13.2. Access Restrictions

Access to personal data is restricted to authorised personnel, contractors and service providers who require the information for a legitimate operational, technical, support, security, legal or compliance purpose.

Persons authorised to access personal data are subject to appropriate confidentiality, access-management and information-security obligations.

Access permissions may be reviewed, limited or withdrawn where they are no longer required.

13.3. Security Monitoring

METROTEXT LIMITED may monitor Account activity, login activity, transactions, device and network information, technical logs and security events where reasonably necessary to protect the Service.

Such monitoring may be used to identify unauthorised access, suspected fraud, duplicate Accounts, payment misuse, automated activity, exploitation of technical errors and other conduct prohibited by the Terms of Service.

Security monitoring will be limited to what is reasonably necessary and proportionate to the relevant security or fraud-prevention purpose.

13.4. Third-Party Service Providers

Where personal data is processed by an authorised service provider on behalf of METROTEXT LIMITED, we take reasonable steps to assess whether the provider maintains appropriate technical and organisational safeguards.

Service providers acting as processors are required to handle personal data in accordance with documented instructions, applicable contractual obligations and data protection requirements.

Payment Providers and other organisations acting as independent controllers are responsible for the security of personal data processed within their own systems.

13.5. Personal Data Breaches and Security Incidents

METROTEXT LIMITED maintains procedures for identifying, recording, assessing, containing and responding to suspected personal data breaches and security incidents.

Where a personal data breach is likely to create a risk to the rights and freedoms of individuals, METROTEXT LIMITED will notify the competent supervisory authority without undue delay and, where feasible, within seventy-two hours after becoming aware of the breach.

Where a breach is likely to create a high risk to affected individuals, METROTEXT LIMITED will also inform those individuals without undue delay, unless an applicable legal exception applies.

Personal data breaches will be documented in accordance with applicable law, including relevant facts, effects and remedial measures.

13.6. User Responsibilities

Users are responsible for maintaining the confidentiality of their Account credentials and for taking reasonable measures to prevent unauthorised access to their Accounts.

Users must not share passwords or authentication information with another person and should use a strong and unique password for Mitronex.

Users should notify METROTEXT LIMITED promptly at support@mitronex.com if they become aware of unauthorised Account access, suspected credential compromise, fraudulent activity or another security incident affecting their Account.

METROTEXT LIMITED may require a password reset, additional verification or temporary Account restriction where reasonably necessary to protect the User or the Service.

13.7. No Absolute Security Guarantee

Although METROTEXT LIMITED applies measures designed to protect personal data, no method of internet transmission, electronic storage or information processing can guarantee absolute security.

Users should exercise appropriate care when submitting personal data online and when accessing the Service through shared, public or unsecured devices and networks.

Nothing in this section reduces METROTEXT LIMITED's obligations to maintain security measures appropriate to the risks associated with its processing activities.

14. Children's Privacy

Mitronex is intended exclusively for individuals who are at least eighteen years old. Persons under eighteen must not create an Account, select an Access Package, use M-Coins or otherwise use the Service.

METROTEXT LIMITED does not knowingly collect or process personal data relating to persons under eighteen.

We may use reasonable age-confirmation or verification measures where necessary to enforce the age restriction, protect the Service or investigate information suggesting that an Account may belong to a minor.

Where we reasonably determine that personal data has been submitted by or relates to a person under eighteen, we may restrict or terminate the relevant Account and delete the information where appropriate.

Certain information may be retained where necessary to document the issue, prevent repeated registration, comply with legal obligations, process a valid refund or establish, exercise or defend legal claims.

A parent, guardian or other person who believes that a minor has provided personal data to METROTEXT LIMITED may contact support@mitronex.com.

The request should provide sufficient information to allow us to identify the relevant Account or personal data. We may request reasonable verification of the requester's identity and authority before disclosing information or taking action.

15. Changes to This Privacy Policy

METROTEXT LIMITED may update this Privacy Policy to reflect changes in applicable law, regulatory guidance, Service functionality, service providers, security practices or personal data processing activities.

The updated Privacy Policy will be published on mitronex.com and will identify the date on which the revised version becomes effective.

Where a change materially affects how personal data is processed, METROTEXT LIMITED may provide additional notice through the Website, an Account notification, email or another appropriate communication method.

Where a new or changed processing activity requires consent, METROTEXT LIMITED will request that consent before carrying out the relevant processing.

An update to this Privacy Policy does not retrospectively authorise processing that lacked an appropriate lawful basis when it was carried out.

Users are encouraged to review this Privacy Policy periodically to remain informed about how METROTEXT LIMITED processes and protects personal data.

Nothing in this section limits any right available under applicable data protection law.

16. Contact Information

Questions concerning this Privacy Policy, the processing of personal data, privacy rights or a privacy-related complaint may be submitted to METROTEXT LIMITED using the following contact details.

METROTEXT LIMITED
Registered office: International House, 101 King's Cross Road, London, England, WC1X 9LP
Company number: 16905638
Email: support@mitronex.com
Telephone: +447822843950

Requests should contain sufficient information to identify the requester, the relevant Account and the nature of the inquiry. METROTEXT LIMITED may request reasonable additional information to verify identity or authority before responding.

METROTEXT LIMITED will review and respond to privacy requests within the timeframes required by applicable data protection law.

Users also have the right to submit a complaint to the Information Commissioner's Office in the United Kingdom or, where applicable, another competent data protection supervisory authority.

Contacting METROTEXT LIMITED first is encouraged but is not a condition for exercising that right.