The following document outlines how MPM Products Limited, along with our subsidiaries, collect, use and protect your personal data across all our websites (applaws.co.uk, encore.co.uk and mpmproducts.com) and digital platforms (“Websites”) and when you contact us by phone, email or social media. For the purposes of the General Data Protection Regulation and UK Data Protection laws MPM Products Limited is the ‘data controller’.
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||MPM Products Limited and our subsidiaries (including applaws.co.uk and encore.co.uk)|
|Data Protection Leadfirstname.lastname@example.org|
|Personal information||Any information relating to an identified or identifiable living individual|
What information is being collected?
Whilst you are using our Website we may ask you for some personal data, such as your name, email address, address and phone number, demographic information such as your age, gender, location, product preferences and interests in relation to customer surveys, offers, newsletters and competitions or when you make an online purchase or register to join.
We will also collect payment information, including transaction and payment card information, credit profile, transaction history and bank details when you purchase goods or services from us.
We may also collect details of the pages you visited on our Website, your IP address, devices you use and Website address you used to access our Website or applications to serve your location and tailor our Websites to you. We may also collect information about how you use our Website, mobile applications, IT, communication and other systems.
Who is collecting the data?
All personal data collected when using our Websites, other platforms or placing orders for goods and/or services will be collected by us.
How is the data collected?
We collect most of this personal information directly from you, in person, by telephone, email, business documents or from your employer if you are a contractor. We also collect personal data across our Websites and digital platforms as you use the sites. Personal data collection, for example, takes place during the following actions, registering your details, entering competitions, signing up to newsletters and purchasing of our products.
Additionally, your personal data may be collected via our systems, for example door entry systems and reception logs, automated monitoring of our websites and other technical systems (such as our computers), networks and connections, CCTV and access control systems, communications systems and email.
We may also collect data in the following ways:
We may collect information about your device including, where available, your Internet Protocol address, to protect against fraud, and your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
How is the data stored / secured?
Your personal data and privacy is of the utmost priority to us. We are committed to ensure that any data/information gathered is securely stored. To ensure no personal data is collected or disclosed accidentally or any unauthorised access is gained, we have implemented the necessary physical, electronic and managerial procedures to safeguard and secure the personal data we collect online.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Websites; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try and prevent unauthorised access.
How and why we use your personal data?
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party;
- allow you to participate in interactive features of our Websites, when you wish;
- ensure that the Website’s content is presented in the best way for you/your device;
- process and deal with any enquiries made by you; and
- where you or your parent or legal guardian (if under the age of 16) have given consent.
|What we use your personal information for||Our reasons|
|To provide goods and services to you||For the performance of our contract with you, or to take steps at your request before entering into a contract|
|To obtain products and/or services from you and/or your employer||For the performance of our contract with you, your employer or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you or your employer/employee||For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you and/or your employer/employees|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
|Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Preventing unauthorised access and modifications to systems||For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
|Updating and enhancing client records||For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, business administration and staff assessments (including contractors)||To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
|Marketing our services and those of selected third parties to:
||For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers|
|External audits and quality checks, e.g. for accreditations and the audit of our accounts||To comply with our legal and regulatory obligations|
How long we keep your data
The length of time for which we will securely store any personal data you share with us will depend on the type of personal data and the purpose for which it is being held. The following are indicative periods for which we will retain your personal data:
- Where we are holding your personal data as a member of our breeders’ club, for so long as you continue to be a member of such club.
- Where we are holding your personal data to sharing our newsletter with you, for so long as you consent to receive such communications.
- Where we are holding your personal data for payment processing reasons, 6 years following the collection of such personal data for accounting purposes.
- Where we are holding your personal data after you have contacted us for customer service reasons, we will retain your information for a 6 year period as is necessary to ensure that your query has been dealt with fully and properly in accordance with our usual standards.
We will not retain your personal information for longer than necessary for the purposes set out in this policy.
Where you have subscribed to receive marketing material from us we will keep your personal data for 12 months from the point at which you invite us to send you communications or from the point at which you interact with you, unless you unsubscribe.
Sharing your data
We will not sell your personal information with any third party organisations. However, to provide our goods and services to you we need to share personal information, where necessary, with:
- those that supply us with goods and services (such as logistic providers);
- marketing agents, mailing list providers;
- payment processors and other financial companies;
- other professional advisers, barristers, auditors, bankers and insurers and brokers, credit reference agencies;
- HM Revenue & Customs, regulators and other authorities who may require us to report processing activities in certain circumstances; and
- IT software providers that host our website and store/maintain data for us.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you, unless you agree otherwise. We may also share personal information with external auditors. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
To deliver services to you, it may become necessary share your personal information outside the UK or the European Economic Area (EEA). We may do this if our service providers are located outside the UK or EEA. If we do transfer your data out of the UK or the EEA, such transfers will be subject to special rules under European and/or UK data protection law.
If you accept/give your consent to cookies from our website, your personal data may also be transfer to selected third parties outside of the UK and EEA. For further details see our cookies policy.
Where you indicate you would like to receive marketing correspondence from us, subscribe to our mailing lists, newsletters, promotional emails, enter any of our competitions or give us your details at any events we hold or attend, we may use personal data for our legitimate interests in order to provide you with details of our goods, services and business updates and events which we think may interest you. We may also share your personal data with organisations who jointly deliver events with us or delegates from those events (with your consent).
We will always ask you to opt-in to marketing information we send to you. You have the right to opt-out of receiving the information detailed at any time. To opt-out of receiving such information you can:
- click on the unsubscribe button in any electronic marketing communication; or
- email us at email@example.com
Our Websites may contain links to, and be linked from other websites. If you follow a link to other websites, they will apply different privacy policies, which you should read. We do not accept any responsibility or liability for them.
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data|
|Data portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to Data Compliance
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Post – MPM Products Ltd,
Trident 3 Business Park,
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
You have the right to lodge a complaint with the Information Commissioner’s who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.