Effective date: July 10, 2026
This Privacy Policy explains how IP Provenance Custody LLC, a Delaware limited liability company, Delaware file no. 10465451 (Midascircle), collects, uses, discloses, and protects personal information through midascircle.com and its related pages (the Site).
It is intended to provide information required or recommended under applicable privacy laws, including the EU General Data Protection Regulation (GDPR), the Law of Ukraine On Personal Data Protection, and applicable United States privacy laws.
The controller or business responsible for personal information processed through the Site is:
IP Provenance Custody LLC
Delaware file no. 10465451
Contact office: Grzybowska 87, Wola, Warsaw 00-844, Poland
Email: info@midascircle.com
We have not appointed a data protection officer unless applicable law requires otherwise. Privacy requests may be sent to the email above.
When you submit the contact form or communicate with us, we may collect:
Please do not submit sensitive personal information or confidential information unless requested and protected by an appropriate written agreement.
When you visit the Site, our hosting and technical service providers may process:
We do not intentionally collect precise geolocation, government identifiers, payment-card information, health data, biometric data, or information from children through the Site.
We process personal information to:
For individuals in the EEA, United Kingdom, or other jurisdictions requiring a legal basis, we rely as applicable on:
We may disclose personal information only as reasonably necessary to:
The Site is hosted and operated using Webflow, Inc. Webflow may process contact-form submissions, technical logs, and related information as our service provider or processor. Webflow describes its practices and subprocessors at webflow.com/legal/privacy and webflow.com/legal/subprocessors.
We do not sell personal information for money. We do not use information submitted through the Site for cross-context behavioral advertising, and we do not knowingly share it for such advertising.
Midas is organized in the United States, maintains an international presence, and uses service providers that may process information in the United States, European Union, United Kingdom, Ukraine, and other countries.
Where required, we use legally recognized safeguards for international transfers, such as adequacy decisions, standard contractual clauses, contractual protections, or other lawful transfer mechanisms. You may contact us for information about applicable safeguards.
We retain personal information only as long as reasonably necessary for the purposes described in this Policy, including to respond to and manage inquiries, maintain appropriate business records, meet legal obligations, resolve disputes, and enforce agreements.
As a general guideline, routine inquiries that do not lead to an engagement are retained for up to 24 months after the last substantive communication, unless a shorter or longer period is appropriate because of consent, an ongoing relationship, a legal obligation, a dispute, security needs, or another documented reason. Technical logs are generally retained for shorter periods determined by operational and security needs.
We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. No internet transmission or storage system is completely secure, and we cannot guarantee absolute security. You are responsible for choosing what information to send through the Site.
The Site and its hosting provider may use strictly necessary technologies for security, network management, load balancing, form operation, language settings, and other essential functions. These technologies may operate without consent where permitted by law.
Optional analytics, advertising, or third-party cookies will be used only as described in an applicable notice and, where required, after your consent. If optional cookies are enabled, the Site should provide a mechanism to accept, reject, and manage them. You may also control cookies through your browser, although blocking necessary technologies may affect Site functionality.
The Site contains links to third-party services such as LinkedIn, X, and Google Maps. Those services may process information when you follow a link or interact with their content under their own policies.
Depending on your location and applicable law, you may have rights to:
EEA and Polish individuals may complain to their local supervisory authority, including Poland's President of the Personal Data Protection Office (UODO). Individuals in Ukraine may contact the Ukrainian Parliament Commissioner for Human Rights where applicable.
To exercise a right, email info@midascircle.com with the subject “Privacy Request.” We may request information reasonably necessary to verify your identity and authority. Authorized agents may submit requests where permitted by law. We will not discriminate against you for exercising applicable privacy rights.
These rights are not absolute. We may decline or limit a request where permitted by law and will explain the basis where required.
During the preceding 12 months, we may have collected the categories described in Section 2, including identifiers, internet or network activity, approximate location derived from IP address, professional information voluntarily provided, and correspondence. We use and disclose these categories for the business purposes described in Sections 3 and 4.
We do not knowingly sell personal information or share it for cross-context behavioral advertising. We do not knowingly process sensitive personal information for purposes requiring a right to limit under California law. If our practices change, we will update this Policy and provide required choices.
California residents may also request information about categories of personal information collected, sources, purposes, categories of recipients, and specific pieces of information, subject to applicable thresholds, exceptions, and verification requirements. California's “Shine the Light” law may provide additional rights concerning disclosure for third parties' direct-marketing purposes; we do not disclose contact-form information for such purposes.
The Site is intended for a professional and general adult audience and is not directed to children under 16. We do not knowingly collect personal information from children. If you believe a child provided personal information, contact us so we can take appropriate action.
We do not use information collected through the Site to make decisions based solely on automated processing that produce legal or similarly significant effects concerning individuals.
The Site may link to third-party websites and services. We are not responsible for their privacy practices. Review their policies before providing personal information.
We may update this Policy to reflect changes in law, technology, or our practices. The revised version will be posted with a new effective date. We will provide additional notice where required for material changes.
For privacy questions or requests:
IP Provenance Custody LLC
Delaware file no. 10465451
Grzybowska 87, Wola, Warsaw 00-844, Poland
Email: info@midascircle.com