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WEBSITE PRIVACY POLICY

This privacy policy sets out how MBM Commercial ("us" / "we") collect, use and discloses personal data.  MBM Commercial respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW YOUR PERSONAL DATA IS COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA INCLUDING OUR LAWFUL BASES
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS

 

1. IMPORTANT INFORMATION AND WHO WE ARE

This privacy policy aims to give you information on how MBM Commercial collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, use our Contact Us form, sign up to our Holistic HR or GDPR Audit services.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and notices and is not intended to override them.

Controller

MBM Commercial is the data controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy.)

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact Details:

Andy Harris, Partner, IP Data & Contracts (“Data Privacy Manager”)
T. 0131 2268208
andy.harris@mbmcommercial.co.uk

MBM Commercial LLP
Edinburgh Office
5th Floor, 125 Princes Street, Edinburgh, EH24AD
T. 08082749540
F. 0131 2268240

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please consider contacting us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated in April 2018.

The data protection law in the UK will change on 25 May 2018. Although this privacy policy sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests until May 2018 as we are still working towards getting our systems ready for some of these changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

WHAT IS PERSONAL DATA?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, title, company name
  • Contact Data includes email address and telephone numbers.
  • Technical Data including internet protocol (IP) address
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also automatically collect the following non-personally identifiable information:

  • Other technical information including the type of browser you are using, the type of operating system you are using, the domain name of your Internet Service Provider. Note that this is not personal data. We use this information to improve the design and content of our website.
  • Usage Data which includes information about how you use our website and services.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your personal data including whilst using our website or otherwise.

This includes any personal data you provide when you:

  • send us queries or contact us using our Contact Us form or register on the Seed Investment area of our website;
  • request marketing to be sent to you;
  • give us feedback; or
  • communicate with us about anything else by post, phone, email or otherwise.

Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data and/or Usage Data. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

4. HOW WE USE YOUR PERSONAL DATA INCLUDING OUR LAWFUL BASES

All personal data processed by us must be:

  • processed lawfully, fairly and transparently;
  • obtained for specific and lawful purposes;
  • be adequate, relevant and limited to what is necessary for our processing purpose;
  • be kept accurate and up to date;
  • not be kept for longer than necessary for the purposes for which it is processed;
  • be kept secure to prevent unauthorised processing and accidental loss, damage or destruction.

 

We will only use your personal data when the law allows us to and we need to inform you of our lawful basis for processing. Most commonly, we will use your personal data in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We provide further details on this below.
  • Where we need to comply with a legal or regulatory obligation.
  • Where we have your consent.

More specific details on our use of your personal data is set out in the table below.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA AND OUR LAWFUL BASES

We have set out below, in a table format, a description of all the ways we currently use and plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please  if you need details about the specific lawful ground we are relying on to process your personal data where more than one ground has been set out in the table below.

The table below provides a summary: (i) the purpose for which we use your personal data; (ii) the categories of personal data that we collect and (iii) our lawful basis for processing your personal data:

Purpose/Activity

Categories of Data

Lawful Basis

To respond to any query you make via our website using our Contact Us form

(a) Identity data (name, title, company name)

(b) Contact data (Email address, phone number)

Additional information may be processed if you provide it to us, for example when letting us know what areas you are interested in, how and when you want to be contacted. If you choose you may also provide us with special category data.

Necessary for our legitimate interest (for running our business, providing our services)

To respond to any query you make via our website using our Seed Investment interest form

(a) Identity data (name, title, company name)

(b) Contact data (Email address, phone number)

Additional information may be processed if you provide it to us, for example when letting us know what areas you are interested in, how and when you want to be contacted

Necessary for our legitimate interest (for running our business, providing our services)

To respond to any query you make by email

(a) Identity data (name, title, company name)

(b) Contact data (Email address, phone number)

Additional information may be processed if you provide it to us, for example when letting us know what areas you are interested in, how and when you want to be contacted

Necessary for our legitimate interest (for running our business, providing our services)

To respond to a request by you to be informed about our events

(a) Identity data (name, title, company name)

(b) Contact data (Email address, phone number)

Additional information may be processed if you provide it to us, for example when letting us know what areas you are interested in, how and when you want to be contacted

Necessary for our legitimate interest (for running our business, providing our services and for marketing purposes, to develop our services and grow our business)

To use data analytics to improve our website, services, marketing, customer relationships and experiences

(a) Technical data (including internet protocol (IP) address)

(b) Usage data (information about how you use our website and services)

Necessary for our legitimate interest (to keep our website updated and relevant, to develop our business and to inform our marketing strategy) (essential cookies)

Consent (non-essential cookies)

Please see our Cookie Policy for further information

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy

(a)Identity data (name, title, company name)

(b)Contact data (Email address, phone number)

Necessary to comply with a legal obligation

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a)Identity data (name, title, company name)

(b)Contact data (Email address, phone number)

 (c)Technical data (including internet protocol (IP) address)

Necessary for our legitimate interest (for running our business, provision of administration and IT services, network security and to prevent fraud)

Marketing

You may receive marketing communications from us if you (i) have requested marketing communications from us, (ii) have consented to marketing communications from us, or (iii) have paid for services from us, and we have assessed that it is in our legitimate interest to send you relevant marketing information that we think you would be interested in, in order to continue to run and grow our business.

If relying on legitimate interest we will always ensure that our interest in doing so has been balanced against any potential impact on you (both positive and negative) and your rights before we process your personal data. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

In each case, we will not send any marketing communications if you have asked us to stop contacting you or opted out of receiving that marketing.

Objecting to or Opting Out of Marketing

You can ask us to stop sending you marketing messages at any time. The unsubscribe option will be in every marketing email that you receive, or you can update your marketing preferences by contacting us at marketing@mbmcommercial.co.uk

 

Cookies

This website uses cookies to help it function and to improve it.  Cookies are small files saved to the user’s computer’s hard drive that track, save and store information about the user’s interactions and usage of the website.  Essential cookies are used to enable our website to function.  Non-essential cookies are used to better understand the users’ experience while visiting the website.  This allows the website, through its server, to provide the users with a tailored experience within this website.

Users are advised that if they wish to deny the use and saving of cookies from this website onto their computer’s hard drive they should take necessary steps within their web browser’s security settings to block all cookies from this website and its external serving vendors or use the cookie control system if available upon their first visit.

For more detailed information about the cookies we use, please see our Cookie Policy.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Privacy Manager.   

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURE OF YOUR PERSONAL DATA

We may have to share your personal data with third parties for the purposes set out in the table in paragraph 4 above. We only share your personal data with service providers acting as processors who provide IT and system administration services and marketing services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We do not currently transfer any personal data gathered via our website outside the European Union (EU).

7. DATA SECURITY

The safety of your personal data is of utmost important to us. As such, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We have an internal data privacy policy which all staff must comply with.

8. DATA RETENTION

How long will you use by data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Data you give us using our Contact Us form and Seed Investment Registration form will only be retained for 60 days before it is deleted, unless you go onto become a client in which case your personal data will be held in accordance with our internal Data Retention Policy.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may be able to:

Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right to withdraw consent

andy.harris@mbmcommercial.co.uk " />In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you wish to exercise any of the rights set out above, please contact our Data Protection Manager, Andy Harris, Partner, IP Data & Contracts (“Data Privacy Manager”) at

andy.harris@mbmcommercial.co.uk

 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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