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

Transcription

1 PRIVACY POLICY Intrductin Yur privacy and trust are imprtant t us and this Privacy Plicy ( Plicy ) prvides imprtant infrmatin abut hw TM Grup Limited ( Cmpany we r us ) handles persnal infrmatin. We are the cntrller and are respnsible fr yur persnal infrmatin. This Plicy applies t persnal infrmatin which we prcess in the curse f ding business with yu, including when yu purchase a prduct r service frm us (cllectively, ur Services ). We will als cllect persnal infrmatin prvided by yu thrugh the Cmpany s website, even if yu are nt a custmer, fr example when yu sign up t ur newsletter. Please read this Plicy carefully and cntact us if yu have any questins abut ur privacy practices r yur persnal infrmatin chices. [This website may include links t third-party websites, plug-ins and applicatins. Clicking n thse links r enabling thse cnnectins may allw third parties t cllect r share data abut yu. We d nt cntrl these third-party websites and are nt respnsible fr their privacy statements. When yu leave ur website, we encurage yu t read the privacy ntice f every website yu visit.] It is imprtant that yu check back ften fr updates t this Plicy. If we make changes we cnsider t be imprtant, we will let yu knw by placing a ntice n ur website and/r cntacting yu using ther methds such as . This Plicy was last updated n 25th May [THE DATA WE COLLECT ABOUT YOU] 2. [HOW IS YOUR PERSONAL INFORMATION COLLECTED] 3. [HOW WE USE YOUR PERSONAL INFORMATION] 4. [DISCLOSURES OF YOUR PERSONAL INFORMATION] 5. [INTERNATIONAL TRANSFERS] 6. [DATA SECURITY] 7. [DATA RETENTION] 8. [YOUR LEGAL RIGHTS] 1. The data we cllect abut yu Persnal infrmatin means any infrmatin abut an individual frm which that persn can be identified. It des nt include data where the identity has been remved (annymus data). We may cllect, use, stre and transfer different kinds f persnal infrmatin abut yu which we have gruped tgether as fllws: Identity Data includes first name, maiden name, last name, username r similar identifier, marital status, title, date f birth and gender.

2 Cntact Data includes billing address, address and telephne numbers. Financial Data includes bank accunt and payment card details. Transactin Data includes details abut payments t and frm yu and ther details f prducts and services yu have purchased frm us. Technical Data includes internet prtcl (IP) address, yur lgin data, brwser type and versin, time zne setting and lcatin, brwser plug-in types and versins, perating system and platfrm and ther technlgy n the devices yu use t access this website. Prfile Data includes yur username and passwrd, purchases r rders made by yu, yur interests, preferences, feedback and survey respnses. Usage Data includes infrmatin abut hw yu use ur website, prducts and services. Marketing and Cmmunicatins Data includes yur preferences in receiving marketing frm us, including hspitality event preferences and ur third parties and yur cmmunicatin preferences. When smene visits ur website we use a third party service, Ggle Analytics, t cllect standard internet lg infrmatin and details f visitr behaviur patterns ( Aggregated Data ). We d this t find ut things such as the number f visitrs t the varius parts f the site. Aggregated Data may be derived frm yur persnal infrmatin but is nt cnsidered persnal infrmatin in law as this data des nt directly r indirectly reveal yur identity. Fr example, we may aggregate yur usage data t calculate the percentage f users accessing a specific website feature. Hwever, if we cmbine r cnnect Aggregated Data with yur persnal infrmatin s that it can directly r indirectly identify yu, we treat the cmbined data as persnal infrmatin which will be used in accrdance with this privacy ntice. We d nt cllect any Special Categries f Persnal Infrmatin abut yu (this includes details abut yur race r ethnicity, religius r philsphical beliefs, sex life, sexual rientatin, plitical pinins, trade unin membership, infrmatin abut yur health and genetic and bimetric data). Nr d we cllect any infrmatin abut criminal cnvictins and ffences. If yu fail t prvide persnal infrmatin: Where we need t cllect persnal infrmatin by law, r under the terms f a cntract we have with yu and yu fail t prvide that data when requested, we may nt be able t perfrm the cntract we have r are trying t enter int with yu (fr example, t prvide yu with Services). In this case, we may have t cancel a service yu have with us but we will ntify yu if this is the case at the time.

3 2. Hw is yur persnal infrmatin cllected? We use different methds t cllect data frm and abut yu including thrugh: Direct interactins. Yu may give us yur Identity, Cntact and Financial Data by filling in frms r by crrespnding with us by pst, phne, r therwise. This includes persnal infrmatin yu prvide when yu: apply fr ur Services; create an accunt n ur website; subscribe t ur service r publicatins; request marketing t be sent t yu; enter a cmpetitin, prmtin r survey; r give us sme feedback. Autmated technlgies r interactins. As yu interact with ur website, we may autmatically cllect technical data abut yur equipment, brwsing actins and patterns. Third parties r publicly available surces. In additin t cllectin f technical data, we may receive persnal infrmatin abut yu frm varius third parties including public recrds and Scial media as set ut belw; Cntact, Financial and Transactin Data frm prviders f technical, payment and delivery services Identity and Cntact Data frm publicly availably surces such as Cmpanies Huse, Register f Inhibitins and the Electral Register based inside the EU. 3. Hw we use yur persnal infrmatin We will nly use yur persnal infrmatin when the law allws us t. Mst cmmnly, we will use yur persnal infrmatin in the fllwing circumstances: Where we need t perfrm the cntract we are abut t enter int r have entered int with yu. Where it is necessary fr ur legitimate interests (r thse f a third party) and yur interests and fundamental rights d nt verride thse interests. Where we need t cmply with a legal r regulatry bligatin. Please nte that we may prcess yur persnal infrmatin withut yur knwledge r cnsent, in cmpliance with data prtectin rules, where this is required r permitted by law. Further detail n the circumstances in which we share persnal infrmatin is set ut belw. Custmers We will cllect and stre persnal infrmatin including cntact details f ur custmers and thse emplyees f the custmer wh are invlved in instructing us s that we can prvide ur Services in accrdance with ur cntract with yu.

4 We may als cllect and stre persnal infrmatin abut emplyees f the custmer fr whm we are prviding Services. This infrmatin may include names, cntact details and/r jb rle. We are prcessing this infrmatin n behalf f ur custmer in rder t prvide them with the Services. Unless yu request us nt t d s, we may als cntact thse emplyees f the custmer wh are invlved in instructing us n an individual basis abut similar services which we ffer, this cntact may be made by telephne, r pst. We will nly d this if it is necessary fr ur legitimate interests. We will nt send yu general marketing infrmatin as part f a grup ing campaign unless yu have cnsented t be cntacted in this way. Suppliers We will cllect and stre persnal infrmatin including cntact details f ur suppliers and thse emplyees f the supplier wh are invlved in the delivery f the Services t ur custmers s that we can receive yur gds r services in accrdance with ur cntract with yu. We may als cntact yu abut new business pprtunities fr us t wrk tgether with yu and t keep yu infrmed f ur activities. We will nly d this if it is necessary fr ur legitimate interests and yur interests d nt verride ur interests. We will nt send yu general marketing infrmatin as part f a grup ing campaign unless yu have cnsented t be cntacted in this way. Third parties We will cllect and stre persnal infrmatin including cntact details f third parties with whm we are in cntact during the delivery f Services t ur custmers r discussins relating t prspective custmers. We prcess that infrmatin because it is in ur legitimate interests t d s in rder fr us t be able t perfrm ur cntracts fr ur custmers r pitch fr wrk frm prspective custmers. We believe that yu wuld reasnably expect us t prcess yur persnal infrmatin in this way and that yur interests d nt verride ur interests. We may als cntact yu abut new business pprtunities fr us t wrk tgether with yu and t keep yu infrmed f ur activities. We will nly d this if it is necessary fr ur legitimate interests and yur interests d nt verride ur interests. We will nt send yu general marketing infrmatin as part f a grup ing campaign unless yu have cnsented t be cntacted in this way. Prspective custmers r prspective suppliers We will cllect and stre persnal infrmatin including cntact details f peple wh we might d business with as a supplier r a custmer. We may cllect this infrmatin frm yu, when yu cntact us (including thrugh this website). We will nly cllect cntact infrmatin frm yur website r anther third party website if we have identified yu specifically as smene wh may be interested in receiving services frm us r delivering gds r services t us. Fr persnal infrmatin which is cllected n prspective custmers r prspective suppliers, we may cntact yu abut new business pprtunities fr us t wrk tgether with yu and t keep yu infrmed f ur activities. We will nly d this if it is necessary fr ur legitimate interests and yur interests d nt verride ur interests.

5 We will nt send yu general marketing infrmatin as part f a grup ing campaign unless yu have cnsented t be cntacted in this way. We have set ut belw, in a table frmat, a descriptin f all the ways we plan t use yur persnal infrmatin, and which f the legal bases we rely n t d s. We have als identified what ur legitimate interests are where apprpriate. Nte that we may prcess yur persnal infrmatin fr mre than ne lawful grund depending n the specific purpse fr which we are using yur data. Please cntact us if yu need details abut the specific legal grund we are relying n t prcess yur persnal infrmatin where mre than ne grund has been set ut in the table belw. Purpse/Activity Type f data Lawful basis fr prcessing including basis f legitimate interest T register yu as a new custmer T prcess and deliver yur rder including: (a) Manage payments, fees and charges (b) Cllect and recver mney wed t us T manage ur relatinship with yu which will include: (a) Ntifying yu abut changes t ur terms r privacy plicy (b) Asking yu t leave a review r take a survey (c) Invitatin t a hspitality event T enable yu t partake in a prize draw, cmpetitin r cmplete a survey (b) Cntact (b) Cntact (c) Financial (d) Transactin (e) Marketing (b) Cntact (c) Prfile (d) Marketing (b) Cntact (c) Prfile (d) Usage (e) Marketing and Cmmunicatins Perfrmance f a cntract with yu (a) Perfrmance f a cntract with yu (b) Necessary fr ur legitimate interests (t recver debts due t us) (a) Perfrmance f a cntract with yu (b) Necessary t cmply with a legal bligatin (c) Necessary fr ur legitimate interests (t keep ur recrds updated and t study hw custmers use ur prducts/services) (a) Perfrmance f a cntract with yu (b) Necessary fr ur legitimate interests (t study hw custmers use ur prducts/services, t develp them and grw ur business)

6 T administer and prtect ur business and this website (including trubleshting, data analysis, testing, system maintenance, supprt, reprting and hsting f data) T deliver relevant website cntent and advertisements t yu and measure r understand the effectiveness f the advertising we serve t yu T use data analytics t imprve ur website, prducts/services, marketing, custmer relatinships and experiences T make suggestins and recmmendatins t yu abut gds r services that may be f interest t yu (b) Cntact (c) Technical (b) Cntact (c) Prfile (d) Usage (e) Marketing (f) Technical (a) Technical (b) Usage (b) Cntact (c) Technical (d) Usage (e) Prfile (a) Necessary fr ur legitimate interests (fr running ur business, prvisin f administratin and IT services, netwrk security, t prevent fraud and in the cntext f a business rerganisatin r grup restructuring exercise) (b) Necessary t cmply with a legal bligatin Necessary fr ur legitimate interests (t study hw custmers use ur prducts/services, t develp them, t grw ur business and t infrm ur marketing strategy) Necessary fr ur legitimate interests (t define types f custmers fr ur prducts and services, t keep ur website updated and relevant, t develp ur business and t infrm ur marketing strategy) Necessary fr ur legitimate interests (t develp ur prducts/services and grw ur business) Opting ut Yu can ask us [r third parties] t stp sending yu marketing messages at any time. Where yu pt ut f receiving these marketing messages, this will nt apply t persnal infrmatin prvided t us as a result f a Service purchase r ther transactin. Ckies The Cmpany and ur third-party prviders set and use ckies and similar technlgies t stre and manage user preferences, deliver targeted advertising, enable cntent, and gather analytic and usage data. Yu can set yur brwser t refuse all r sme brwser ckies, r t alert yu when websites set r access ckies. If yu disable r refuse ckies, please nte that sme parts f this website may becme inaccessible r nt functin prperly. Fr further infrmatin, please see ur Ckie Plicy.

7 4. Disclsures f yur persnal infrmatin The Cmpany shares r disclses persnal infrmatin when necessary t prvide Services r cnduct ur business peratins as described belw. When we share persnal infrmatin, we d s in accrdance with data privacy and security requirements. We d nt sell any persnal infrmatin t third parties. Belw are the parties with whm we may share persnal infrmatin and why. Our business partners: We ccasinally partner with ther rganisatins based in the United Kingdm t deliver the Services, prvide cntent, r t hst events, cnferences, and seminars. As part f these arrangements, yu may be a custmer f bth the Cmpany and ur partners, and we and ur partners may cllect and share infrmatin abut yu. Our third-party service prviders: We partner with and are supprted by service prviders within the United Kingdm. Persnal infrmatin will be made available t these parties nly when necessary t fulfil the gds r services they prvide t us, including (withut limitatin) sftware, system, and platfrm supprt; direct marketing services; clud hsting services; advertising; data analytics; and rder fulfilment and delivery. Our third-party service prviders are nt permitted t share r use persnal infrmatin we make available t them fr any ther purpse than t prvide services t us. We require ur business partners and third party service prviders t respect the security f yur persnal infrmatin and t treat it in accrdance with the law. We d nt allw ur third-party service prviders t use yur persnal infrmatin fr their wn purpses and nly permit them t prcess yur persnal infrmatin fr specified purpses and in accrdance with ur instructins. Third parties fr legal reasns: Third parties t whm we may chse t sell, transfer, r merge parts f ur business r ur assets. Alternatively, we may seek t acquire ther businesses r merge with them. If a change happens t ur business, then the new wners may use yur persnal infrmatin in the same way as set ut in this privacy ntice. 5. Internatinal transfers We d nt transfer yur persnal infrmatin utside the Eurpean Ecnmic Area. 6. Data security We take apprpriate steps t ensure that persnal infrmatin is prcessed, secured, and transferred accrding t applicable law. We have put in place apprpriate security measures t prevent yur persnal infrmatin frm being accidentally lst, used r accessed in an unauthrised way, altered r disclsed. Our infrmatin security plicies and prcedures are clsely aligned with widely accepted internatinal standards and are reviewed regularly and updated as necessary t meet ur business needs, changes in technlgy, and regulatry requirements. In additin, we limit access t yur persnal infrmatin t thse emplyees, agents, cntractrs and ther third parties wh have a business

8 need t knw. They will nly prcess yur persnal infrmatin n ur instructins and they are subject t a duty f cnfidentiality. We have put in place prcedures t deal with any suspected persnal infrmatin breach and will ntify yu and any applicable regulatr f a breach where we are legally required t d s. 7. Data retentin We retain persnal infrmatin fr as lng as we reasnably require it fr legal r business purpses. In determining data retentin perids, the Cmpany takes int cnsideratin lcal laws, cntractual bligatins, and the expectatins and requirements f ur custmers and suppliers. When we n lnger need persnal infrmatin r when yu request us t delete yur infrmatin, where this is legal, we will securely delete r destry it. The length f time that we keep custmer and supplier files will depend n the nature f the gds and services prvided r received. We will nly retain yur persnal infrmatin fr as lng as necessary t fulfil the purpses we cllected it fr, including fr the purpses f satisfying any legal, accunting, r reprting requirements. Details f retentin perids fr different aspects f yur persnal infrmatin are available upn request by using the Cntact Us ptin n ur website. 8. Yur legal rights We respect yur right t access and cntrl yur infrmatin, and we will respnd t requests fr infrmatin and, where applicable, will crrect, amend, r delete yur persnal infrmatin. Access t persnal infrmatin: If yu request access t yur persnal infrmatin, we will gladly cmply, subject t any relevant legal requirements and exemptins, including identity verificatin prcedures. Befre prviding data t yu, we will ask fr prf f identity and sufficient infrmatin abut yur interactin with us s that we can lcate any relevant data. Crrectin and deletin: Yu have the right t crrect r amend yur persnal infrmatin if it is inaccurate r requires updating. Yu may als have the right t request deletin r transfer f yur persnal infrmatin; hwever, this is nt always pssible due t legal requirements and ther bligatins and factrs. Remember that yu can cntact us abut ur use f yur persnal infrmatin by using the Cntact Us ptin n ur website. Object t prcessing f yur persnal infrmatin: where we are relying n a legitimate interest (r thse f a third party) and there is smething abut yur particular situatin which makes yu want t bject t prcessing n this grund as yu feel it impacts n yur fundamental rights and freedms. Yu als have the right t bject where we are prcessing yur persnal infrmatin fr direct marketing purpses. In sme cases, we may demnstrate that we have cmpelling legitimate grunds t prcess yur infrmatin which verride yur rights and freedms. Request restrictin f prcessing f yur persnal infrmatin. This enables yu t ask us t suspend the prcessing f yur persnal infrmatin in the fllwing scenaris: (a) if yu want us t establish the data's accuracy; (b) where ur use f the data is unlawful but yu d nt want us t erase it; (c) where yu need us t hld the data even if we n lnger require it as yu need it t establish, exercise r defend legal claims; r (d) yu have bjected t ur

9 use f yur data but we need t verify whether we have verriding legitimate grunds t use it. Withdrawal f cnsent: If we are prcessing yur persnal infrmatin n the basis that yu have given yur cnsent t us prcessing that persnal infrmatin, yu have a right t withdraw yur cnsent at any time by using the Cntact Us ptin n ur website. Request the transfer f yur persnal infrmatin t yu r t a third party. We will prvide t yu, r a third party yu have chsen, yur persnal infrmatin in a structured, cmmnly used, machine-readable frmat. Nte that this right nly applies t autmated infrmatin which yu initially prvided cnsent fr us t use r where we used the infrmatin t perfrm a cntract with yu. Filing a cmplaint: If yu are nt satisfied with hw the Cmpany manages yur persnal infrmatin, yu have the right t make a cmplaint t the Infrmatin Cmmissiner s Office ( Children s privacy Our services are nt directed t children under 13. If yu learn that a child under 13 has prvided us with persnal infrmatin withut cnsent, please cntact us. Hw t cntact us Please cntact us with any requests related t yur persnal infrmatin. We understand that yu may have questins r cncerns abut this Plicy r ur privacy practices. Please feel free t cntact us in ne f the fllwing ways: Address: GDPR@tmgrup.c.uk 1200 Delta Business Park Swindn. SN5 7XZ