|Summary – International transfer of Personal Data|
|We transfer Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA to a recipient outside the EEA that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses.|
Because of the international nature of our business, we transfer Personal Data within the MSI group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Policy. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. You are entitled to request a copy of our Standard Contractual Clauses using the contact details provided in Section (R) below.
Please note that when you transfer any Personal Data directly to a MSI entity established outside the EEA, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Policy.
|Summary – Data security|
|We implement appropriate technical and organisational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely.|
We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.
|Summary – Data accuracy|
|We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.|
We take every reasonable step to ensure that:
· your Personal Data that we Process are accurate and, where necessary, kept up to date; and
· any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.
From time to time we may ask you to confirm the accuracy of your Personal Data.
|Summary – Data minimisation|
|We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.|
We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.
|Summary – Data retention|
|We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed in connection with a lawful purpose.|
We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data are as follows:
|(1) we will retain Personal Data in a form that permits identification only for as long as:|
|(a) we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed); or|
|(b) your Personal Data are necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis (e.g., where your personal data are included in a contract between us and your employer, and we have a legitimate interest in processing those data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),|
|(2) the duration of:|
|(a) any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and|
|(b) an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim) ,|
|(3) in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.|
During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:
· permanently delete or destroy the relevant Personal Data; or
· anonymize the relevant Personal Data.
|Summary – Your legal rights|
|Subject to applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. In some cases it will be necessary to provide evidence of your identity before we can give effect to these rights.|
Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:
· the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, Apps, Products, or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
· the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
· the right to request rectification of any inaccuracies in your Relevant Personal Data;
· the right to request, on legitimate grounds:
o erasure of your Relevant Personal Data; or
o restriction of Processing of your Relevant Personal Data;
· the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
· where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive Policy of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
· the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).
Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (R) below. Please note that:
· in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
· where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.
|Summary – Cookies and similar technologies|
|Summary – Direct marketing|
|We Process Personal Data to contact you with information regarding Sites, Apps, Products, or services that may be of interest to you. You may unsubscribe for free at any time.|
We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, Apps, Products, or services that may be of interest to you. If we provide Sites, Apps, Products, or services to you, we may send information to you regarding our Sites, Apps, Products, or services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us, subject always to obtaining your prior opt-in consent to the extent required under applicable law.
You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Apps, Products, or services you have requested.
|Summary – Details of Controllers|
For the purposes of this Policy, the relevant Controllers are:
|Controller entity||Contact details|
Alternatively, you may contact us using our online Contact Us form.
Our Data Protection Officer is contactable using the details set out above.