Privacy Policy – Digital MIAM
Effective Date: 26th October 2025
Last Updated: 29th January 2026
At Digital MIAM, your privacy and trust are critically important to us. This Privacy Policy outlines how we collect, process, store, and protect your personal data when you use our website and services. We are committed to transparency and complying with the UK General Data Protection Regulation (UK GDPR).
1. Who We Are
Digital MIAM is a UK-based digital platform owned and operated by Cypher 7 Limited. We help individuals access the Mediation Information and Assessment Meeting (MIAM) process online, offering intelligent survey tools and mediator matching services.
2. Data We Collect
2.1 We may collect the following types of personal data:
Identity & Contact Information: Name, email address, and contact details provided when signing up or booking.
Case Information: Answers you provide in our MIAM intake survey, which may include sensitive personal and family-related information.
Technical Data: IP address, browser type, device data, and usage statistics for performance and security monitoring.
2.2 Sensitive Personal Data
The nature of family mediation means we may collect information that constitutes "special category data" under UK GDPR, including information relating to:
· Health (physical or mental)
· Children and family circumstances
· Allegations of domestic abuse or safeguarding concerns
· Racial or ethnic origin (where relevant to your case)
We process this data only where:
· You have given explicit consent by submitting your MIAM intake form;
· Processing is necessary for the establishment, exercise, or defence of legal claims;
· Processing is necessary to protect your vital interests or those of another person.
We handle all sensitive data with the highest level of care and confidentiality.
3. Use of AI and Anonymised Case Analysis
Digital MIAM uses artificial intelligence (AI) to analyse MIAM survey responses and assist in case preparation. We apply the following strict safeguards:
No personally identifiable information (PII) is ever transmitted to the AI system.
All survey data is anonymised prior to processing to prevent re-identification.
The AI’s analysis is used solely to support mediators in preparing for your MIAM and to provide you with a structured case summary.
We ensure that AI outputs are reviewed by qualified mediators and are not used as a substitute for professional judgment.
Our AI tools assist in case preparation by analysing anonymised survey responses. However, no solely automated decisions with legal or significant effects are made about you without human review.
All AI-generated outputs are reviewed by qualified mediators before being used in your case. You have the right to request human intervention, express your point of view, and contest any decision that affects you.
4. How We Use Your Information
We process your personal data to:
Deliver, manage, and improve our digital mediation services
Match you with a suitable and qualified mediator
Communicate with you regarding your booking, case progress, or recommendations
Comply with our legal and regulatory obligations
Ensure the security and integrity of our platform
We may share your data with carefully selected third-party partners who offer services related to divorce, family mediation, or post-MIAM support — but only where you have explicitly indicated an interest in receiving such services. These partners are required to comply with data protection obligations.
5. Legal Basis for Processing
We process your data under these legal bases:
Performance of a contract (e.g., to deliver MIAM services)
Your consent (e.g., survey submission)
Our legitimate interests (e.g., improving the platform)
Compliance with legal obligations
6. Data Retention
We retain personal data only as long as necessary to deliver our services or comply with legal requirements. Survey data may be stored for up to 6 years for audit and compliance.
7. Data Security
We use appropriate technical and organisational measures to protect your data from unauthorised access, loss, or misuse. This includes:
Secure cloud infrastructure
Encrypted data storage
Access controls and internal audits
Anonymisation techniques for AI analysis
8. Your Rights Under UK GDPR
You have the right to:
Access your personal data
Correct inaccurate or incomplete data
Request erasure (where legally permitted)
Object to or restrict processing
Request data portability
To exercise any of your rights, please contact us at: contact@digitalmiam.co.uk
9. Third-Party Service Providers (Sub-Processors)
We use trusted third-party service providers to help deliver our services. These providers process personal data on our behalf and are contractually required to protect your data in accordance with UK GDPR.
Our key sub-processors include:
Provider > Supabase Inc.
Purpose > Database hosting and authentication
Location > Data hosted in UK/EU; company headquartered in USA
Provider > OpenAI Inc.
Purpose > Anonymised case analysis
Location > USA
Provider > Stripe Payments UK Limited
Purpose > Payment processing
Location > UK
Provider > Google LLC
Purpose > Communications
Location > USA
We maintain Data Processing Agreements (DPAs) with all sub-processors. A full list of sub-processors is available on request by emailing contact@digitalmiam.co.uk.
10. Cookies
Our website may use cookies and similar tracking technologies to enhance functionality and user experience. You can manage your cookie preferences via your browser settings. For more details, please refer to our Cookie Policy.
11. Children’s Data
Our services are not intended for individuals under the age of 18 without parental or guardian consent. We do not knowingly collect personal data from children without appropriate safeguards.
12. International Data Transfers
Your personal data is primarily stored on servers located within the United Kingdom and European Economic Area.
However, some of our service providers are based in, or have operations in, countries outside the UK, including the United States. Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place, including:
· UK International Data Transfer Agreement (IDTA) or Standard Contractual Clauses (SCCs) approved by the UK Government;
· Transfers to countries with a UK adequacy decision (including the EU and, for certified companies, the USA under the UK Extension to the EU-US Data Privacy Framework);
· Conducting Transfer Impact Assessments where required to evaluate risks.
Our database provider, Supabase Inc., is headquartered in the United States. We have executed a Data Processing Agreement with Supabase that includes Standard Contractual Clauses. Data at rest is stored in UK/EU data centres. We have conducted a Transfer Impact Assessment for this arrangement.
You may request a copy of the safeguards we use for international transfers by contacting us at contact@digitalmiam.co.uk.
13. Data Security Incidents
In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, we will:
· Notify the Information Commissioner's Office (ICO) within 72 hours of becoming aware of the breach, where required by law;
· Notify you directly without undue delay if the breach is likely to result in a high risk to your rights;
· Take immediate steps to contain and remediate the breach.
We maintain incident response procedures and conduct regular security reviews to minimise the risk of breaches.
14. Changes to This Policy
We may update this Privacy Policy from time to time. If material changes are made, we will notify you via our website or by email. Your continued use of the platform constitutes acceptance of the revised policy.
15. Contact Us
If you have questions, concerns, or wish to exercise your rights under this policy, please contact us:
Email: contact@digitalmiam.co.uk
Website: www.digitalmiam.co.uk
Company: Cypher 7 Limited (trading as Digital MIAM), Company Number 13557284
Company Address: Available upon written request