DATA PROTECTION POLICY
WE RESPECT YOUR PRIVACY AND ARE COMMITTED TO PROTECTING YOUR PERSONAL DATA
THE DATA WE COLLECT ABOUT YOU
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). When you complete an online form, register or connect with us online, we may collect, use and store different kinds of personal data about you such as your name, gender, date of birth, current location, employer, email address and telephone number. We may also collect and retain information about your interactions with us either online or through our operating systems so that we can process your system activities and deal with any future queries. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
In certain situations, we can collect and process your data with your consent. In limited situations, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a contractual or legal requirement. We may process your personal data without your knowledge or consent (for example, in relation to fraud management or to assist with investigations by the police or other regulatory bodies) in compliance with the above rules, where this is required or permitted by law.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at [email protected] or by ‘opting out’ of marketing communications in any email sent to you.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Should you wish to unsubscribe to any or all of our marketing material, please contact us at [email protected] or opt out of marketing communications by clicking the ‘unsubscribe’ link in any email sent to you.
THIRD PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company outside of MOGIT for marketing purposes.
THIRD PARTY LINKS
Clicking on links to third-party websites, plug-ins and applications contained within our websites, 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 notice of every website you visit.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out above (in ‘Purposes for which we will use your Personal Data’):
- MOGIT entities, details of which can be found in our Annual Reports
- The licensed operator of the system in use
We may, from time to time, expand, reduce or sell MOGIT and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice. 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.
We have appropriate security measures in place 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 procedures in place 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.
HOW LONG WILL WE USE YOUR PERSONAL 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.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
IF YOU FAIL TO PROVIDE YOUR PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you or your employer and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
DATA PROTECTION OFFICER
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact Data Protection Officer on email [email protected]