MANILAI
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MANILAI / LEGAL

Privacy Policy

Last updated: 19 October 2026

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1. Who we are

MANILAI is a trade name of LED-visuals B.V., Chamber of Commerce number 68026331, Spadesteek 12, 4131 MB Vianen, the Netherlands. VAT: NL857271040B01. We are the controller for the personal data described here. Contact us at info@manilai.com. We have not appointed a data protection officer, as we are not required to.

2. What this policy covers

This policy covers the MANILAI website and the early-access waitlist. It does not cover the MANILAI application, the Smart Pen or the membership; those are not yet available and a separate policy will be published before they are.

3. What we collect, why, and on what basis

WhatWhyLegal basisHow long
Your email addressTo email you when early access becomes availableYour consent, art. 6(1)(a) GDPRUntil you withdraw, or 24 months after the last contact we can see from you — your signup, your confirmation, a reply or a purchase — whichever is first
Your email addressTo send you product updates and offers, if you asked for themYour consent, art. 6(1)(a) GDPRUntil you withdraw, or 24 months after the last contact we can see from you — your signup, your confirmation, a reply or a purchase — whichever is first
Your consent record: what you agreed to, the exact wording, when, in which language, from where, and when you confirmedTo be able to show what you agreed to, which the law requires of usLegal obligation, art. 6(1)(c), and our legitimate interest in defending our position, art. 6(1)(f)For as long as we hold your email address, and 3 years after
An unconfirmed sign-up, if you never confirmTo complete the confirmation step you startedYour consent, art. 6(1)(a)14 days, then deleted
A record that you unsubscribedTo make sure we do not email you again by mistakeLegal obligation, art. 6(1)(c)For as long as we send email at all. We keep the minimum needed to recognise your address
Your message to us and our reply, including your email addressTo handle your question or complaint and to be able to show how we handled itOur legitimate interest in handling enquiries, art. 6(1)(f). For a request about your privacy rights: legal obligation, art. 6(1)(c)General questions and complaints: 2 years. Requests about your privacy rights: 3 years. If it becomes a dispute, until that is resolved
Technical data our platform records, including your IP address, browser and the pages you visitTo keep the website working, secure and free of abuseOur legitimate interest in a working, secure website, art. 6(1)(f)Retention periods vary across Shopify’s internal systems and are governed by Shopify’s applicable retention policies. Shopify has not confirmed a single fixed retention period for these technical and security logs.
Your order: what you bought, the price, your name, delivery and billing address, and your order historyTo perform the contract with you, deliver, invoice and handle returnsPerformance of a contract, art. 6(1)(b) GDPRSeven years from the end of the financial year, because tax law requires it
Your payment: the method, the status and a reference. We never see your full card numberTo take payment and to process a refundPerformance of a contract, art. 6(1)(b)Seven years, as part of our financial administration
Which pages you visit, how long you stay and how you arrived, with an identifier that recognises your browserTo see which pages are read, so we can improve the siteYour consent, art. 6(1)(a) GDPR, given through the cookie bannerUp to 2 years, set by Shopify and Google Analytics. You can withdraw at any time
What you do on our website and in our ads: pages seen, whether you signed up or bought, and an identifier the advertising platform setsTo measure whether our advertising works and to show you relevant adsYour consent, art. 6(1)(a) GDPR, given through the cookie bannerSet by each advertising platform; see their own policies. You can withdraw at any time

We do not ask for your name and we ask nothing else about you when you sign up. That is deliberate: MANILAI is a product about mental performance, and we would rather not collect anything about how you are doing before you have decided to use it.

We do not profile you and we make no automated decisions about you.

4. Confirming your email address

After you sign up we email you to confirm. Until you confirm, we send you nothing else, and if you do not confirm within 14 days we delete the sign-up. The confirmation covers only what you selected; it never adds anything you did not ask for.

5. Who else sees your data

ProviderWhat they doWhere
ShopifyRuns our website and holds the waitlist recordShopify International Limited, Ireland. Our store’s configured data hosting location is the United States. Processing may also involve international transfers under Shopify’s Data Processing Addendum and applicable transfer safeguards.
KlaviyoSends our emails and holds the mailing listKlaviyo. Our mailing-list data are stored in the United States (AWS us-east-1, Northern Virginia). EU data residency is not enabled for our account. Processing may also take place in countries identified in the subprocessor list. Under its Data Processing Agreement, Klaviyo, Inc. relies on the EU–US Data Privacy Framework where applicable. The EU Standard Contractual Clauses apply to transfers within their scope when and for as long as Klaviyo cannot rely on that framework.
DD Lab StudioBuilt the website and supports it for 30 days after launchGeorgia. Access is limited to the website admin and governed by a data processing agreement. No access to waitlist data once the waitlist opens
Meta (Facebook, Instagram)Measures our advertising and builds audiences, only with your consentUnited States and Ireland, under Meta’s terms and transfer mechanism
TikTokMeasures our advertising, only with your consentUnited States and Ireland, under TikTok’s terms and transfer mechanism
Google (Ads, Analytics)Measures our advertising and how the site is used, only with your consentUnited States and Ireland, under Google’s terms and transfer mechanism
Microsoft (Bing Ads)Measures our advertising, only with your consentUnited States and Ireland, under Microsoft’s terms and transfer mechanism
PandectesRuns our cookie banner and stores the record of your cookie choiceEuropean Union, under its data processing agreement

Some of these providers are outside the European Economic Area. Where that is the case the transfer runs on the mechanism in that provider’s data processing agreement, usually the European Commission’s Standard Contractual Clauses. Ask us and we will tell you which applies. We do not sell your data and we do not share it with anyone else unless the law requires it.

6. Cookies and advertising

We place cookies that are strictly necessary to run this website without asking, because there is no alternative to them. We place analytics and advertising cookies only if you agree through the cookie banner. You can change or withdraw your choice at any time through the cookie settings link in the footer, and withdrawing is as easy as agreeing. Our Cookie Policy lists what we place and what each item does.

7. Advertising

We advertise on Meta (Facebook and Instagram), TikTok, Google and Microsoft Bing. If you agree to marketing cookies, these platforms place a tag on our website that tells them you visited, which pages you saw and whether you signed up or bought something. They use that to report how our advertising performed and to show you our ads elsewhere.

For the moment the tag collects and sends your data, we and the platform decide together what happens, which makes us jointly responsible for that step. What the platform does with the data afterwards, for its own purposes, is its own responsibility and is described in its own privacy policy. Arrangements with each platform set out who does what; you can ask us for the essence of those arrangements and you can exercise your rights with us or with the platform.

These platforms are based in the United States and in Ireland. Where data leaves the European Economic Area, the transfer runs on the mechanism in that platform’s terms, usually the European Commission’s Standard Contractual Clauses or an adequacy decision.

You can object to this at any time by withdrawing your consent for marketing cookies. Nothing we place for advertising is necessary to use our website.

We do not use advertising to target people based on health, mental state or anything similar, and we do not give the platforms information that would suggest it. We also never combine our waitlist with an advertising platform without asking you separately first.

8. Your rights

You can ask us to show you what we hold about you, correct it, delete it, restrict what we do with it, object to it, or send it to you or to someone else in a portable format.

Where we rely on your consent you can withdraw it at any time, for either purpose separately or for both at once. That does not affect anything we did before you withdrew it. Every email we send carries a preference link and an unsubscribe link.

Write to info@manilai.com and we will answer within one month. If you are not satisfied you can complain to the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens, at autoriteitpersoonsgegevens.nl, or to the supervisory authority in your own country.

9. Security

The website runs entirely over HTTPS. Access to the waitlist is limited to the people who need it, and those accounts use two-factor authentication. Our signup form is protected against automated abuse by a hidden field that only software fills in; it collects no personal data and involves no third party. Our providers maintain their own measures, set out in their agreements with us.

10. Age

The waitlist is intended for adults. We do not knowingly collect data from anyone under 18. If you believe we have, contact us and we will delete it.

11. Changes

We will update this policy as MANILAI develops, in particular when the application and the Smart Pen become available, and whenever we add or remove an analytics or advertising platform. The date at the top shows when it last changed. We will email people on the waitlist about significant changes that affect them.

Your thoughts are where it begins.

Your thoughts shape your actions. Your actions shape your identity. Your identity shapes your reality.Your thoughts shape your actions.
Your actions shape your identity.
Your identity shapes your reality.

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