SECTION 1 – GENERAL INFORMATION
1.1 Multi Let Cashflow System (MLCS) is referred to in this Privacy Notice as ‘we’, ‘us’, or ‘our’ is a controller for the personal information that it collects and uses about you. Our contact details are set out in section 11 of this Privacy Notice. Any reference in this Privacy Notice to ‘you’ or ‘your’, refers to anyone whose personal information we process. This Privacy Notice is to inform you how we will use your personal information, the legal basis which allows us to use your personal information, how we share your personal information and inform you of your rights in accordance with the laws in place that protect your personal information, including the Data Protection Act 1998, the Privacy and Electronic Communications (EC Direction Regulations 2003) and the General Data Protection Regulation 2016/679 and any subsequent data protection legislation which is implemented in the United Kingdom (together, “Data Protection Legislation”).
1.2 We will treat all of your personal information as confidential and in accordance with the Data Protection Legislation and your personal information will only be shared with others in accordance with this Privacy Notice.
1.3 We keep this Privacy Notice up to date, so if there are any changes to the way in which your personal information is used, this Privacy Notice will be updated.
1.4 The ‘EDGE’ and ‘MLCS SAS’ are associated brands of MLCS. For more information about the brands we operate under and for any updates on the brands in which we operate under please contact us directly.
2 How to use this Privacy Notice
1.1 This Privacy Notice is split into three sections as detailed below:
1.1.1 Section 1: general information applicable to all individuals;
2.1.1 Section 2: information only applicable to Website users; and
2.1.2 Section 3: information only applicable to prospective or actual customers who either purchase a product, service or training, or show an interest in purchasing any products, services or trainings from us.
2.2 Please note, in the event you use the Website services offered by us and purchase a training from us, all sections of this Privacy Notice will be applicable to you.
3 What is personal information?
3.1 Personal information is any information that tells you something about a living individual. This could include information such as name, contact details, account number, date of birth and bank account details.
4 For how long do we keep your personal information?
4.1 We will keep your personal information for 7 years commencing on the date of our last transaction with you to comply with our regulatory obligations. Your personal information will be retained in accordance with our retention policy, your rights under Data Protection Legislation and in line with our regulatory obligations.
4.2 Any personal information will be deleted in accordance with our data retention policy.
5 What is the legal basis of our data processing?
5.1 Under Data Protection Legislation we are only permitted to use your personal information if we have a legal basis for doing so as set out in the data protection legislation. We rely on the following legal bases to use your personal information:
5.1.1 Where you have provided consent for us to process your personal information;
5.1.2 Where processing is necessary to enable us to perform our contract with you or take steps to enter into a contract with you at your request;
5.1.3 Where we need to comply with a legal obligation; and
5.1.4 Where it is necessary for our legitimate interests (of those of a third party) and your interests and fundamental rights do not override those interests.
5.2 In some cases we will need your consent to obtain and use your personal information. When this is the case, we will ask for your consent and we will explain why we need the personal information at the time when we ask for your consent. If we are relying on consent, you can withdraw your consent to our processing of your personal information at any time by contacting us using the contact details below.
5.3 Some information is classified as ‘special’ data under Data Protection Legislation. This includes information relating to, amongst other things, health or information about any disability you may have. This information is more sensitive and we need to have further justifications for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances, such as when processing disability information with regards to accessing a training venue (if applicable).
6 How do we share your personal information?
6.1 We will keep your personal information confidential and only share it with others for the purposes set out below and elsewhere in this Privacy Notice and who agree to only hold such personal information under strict conditions to safeguard your personal information.
6.2 We will share your personal information in the following ways:
6.2.1 We share your personal information with any person working within the company on a need to know basis to ensure we are able to perform our obligations to you;
6.2.2 We share your personal information with any organisation which you have given us permission to share it with;
6.2.3 We share your personal information with any organisation which we have sub-contracted or engaged to provide services on our behalf, including software providers and hosts, postal fulfilment, marketing fulfilment, enquiry management, accounts, tax compliance, accident management, legal and audit, payment processing, training logistics, warranty providers, finance companies and market research.
6.2.4 We may share your personal information for inter-company referral purposes or if you make a complaint, any information needed to settle such complaint;
6.2.5 We may share your personal information with any relevant fulfilment company to allow them to perform any required services for you;
6.2.6 We may pass your personal information to selected third parties and agents who provide administrative support to us.
6.2.7 We may share personal information with our regulators and law enforcement authorities and with courts, tribunals and arbitrators in order to comply with our regulatory and legal obligations; and
6.2.8 We may share personal information in connection with any sale, merger, acquisition, disposal, reorganisation or similar change of our business.
7.1 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 information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
7.2 We have put in place procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.
7.3 Please note that as no data transmission over the Internet can be guaranteed to be 100% secure we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.
8 Overseas transfers of your personal information
8.1 Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
8.2 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
(a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
(b) Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
(c) Where we use service providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en
9 Your rights in relation to your personal information
9.1 You have a number of rights in relation to your personal information, these include the right to:
9.1.1 Be informed about how we use your personal information;
9.1.2 Obtain access to your personal information that we hold;
9.1.3 Request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate;
9.1.4 Request that we erase your personal information in the following circumstances:
(a) If MLCS is continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected;
(b) If MLCS is relying on consent as the legal basis for processing the personal information and you withdraw consent;
(c) If MLCS is relying on legitimate interests as the legal basis for processing the personal information and you object to this processing and there is no overriding compelling ground which enables us continue with the processing;
(d) If the personal information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation); or
(e) If it is necessary to delete the personal information to comply with a legal obligation.
9.1.5 Ask us to restrict our data processing activities where you consider that:
(a) Personal information is inaccurate;
(b) Our processing of your personal information is unlawful;
(c) Where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim; or
(d) Where you have raised an objection to our use of your personal information;
9.1.6 Request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information;
9.1.7 Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and
9.1.8 Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.
9.2 If you would like to exercise any of your rights or find out more, please write to use at firstname.lastname@example.org.
10 Processing your personal information based on consent – Marketing
10.1 If you have consented to receive marketing and/or promotional communications from us you can change your mind and opt out at any time. If you would like to stop receiving marketing and/or promotional communications from us, please contact us using the details below in section 11, or you can click on any of the opt-out links contained in all of our email communication.
11.1 If you have any complaints about the way we use your personal information please contact us at your earliest convenience and we will try to resolve the issue. If we cannot resolve any issue, you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK) via their website www.ico.org.uk. If you need more information about how to contact your local data protection authority please let us know by contacting email@example.com. Or in writing to; MLCS, Bath House, Aller, Somerset, TA10 0QW.
SECTION 2 – WEBSITE USERS
Any reference to Website in this Privacy Notice refers to www.multiletcashflowsystem.com,
1 How do we collect personal information from our Website?
1.1 We collect personal information about you from various sources including:
1.1.1 Web forms located on our Website (including but not limited to, training events, manuals, books, software and video downloads);
1.1.2 Emails we provide to you so that you can contract us with enquiries and send us your details; and
2 What personal information do we collect using our Website?
2.1 We collect the following types of personal information:
2.1.1 Your name, email address, postal address, telephone or mobile number;
2.1.2 Details about any products and services which you have an interest in as offered on our Website; and
2.1.3 Your marketing preferences (including any requests to opt-out of marketing).
2.2 If you give us personal information about somebody else, such as a colleague or family member etc., we will assume you have their permission to do so, and their data will also be subject to this Privacy Notice.
3 For what purposes do we use your personal information from our Website?
3.1 We use your personal information for the following purposes:
3.1.1 To respond to any enquiries or requests you make via our Website
3.1.2 To provide our services to you and to manage our business;
3.1.3 To keep you informed of other services we provide which may be of interest to you (if you have consented to such marketing or an exemption applies), unless you have opted not to receive such information. We will use your name and email address to send the marketing communications to you;
3.1.4 To personalise and improve our services by analysing how many times you visit the Website, analysing your location data and behavioural patterns;
3.1.5 To analyse how users utilise the Website; and
3.1.6 To comply with our legal obligations and professional codes and to identify, prevent or detect fraud or other crimes.
4 Using your personal information for profiling/automated decision making
4.1 We do not use your personal information for profiling or automated decision making.
5 Social Media
5.1 The Website offers you the opportunity the recommend our Website to your friends on third party social media site (for example, through ‘liking’ options).
5.2 We offer this functionality to raise interest about our Website, however please be aware that when sharing information with third party social media sites, your personal information may become public. We recommend you always read the privacy notices of the third party social media site to understand how your data is being used.
6 Links to other website
6.1 Our Website provides links to other sites, which may not be governed by this Privacy Notice and you should view the particular privacy notices of those sites for further information.
SECTION 3 – PROSPECTIVE OR ACTUAL CUSTOMERS
1 How do we collect personal information from you?
1.1 We collect personal information about you from various sources including:
1.1.1 Through the provision of a sale of a training event, manual, book, software or training video.
1.1.2 The personal information you provide us when any contact is made with you (by way of telephone call, email or by any other means) in accordance with the provision of our services;
1.1.3 Any personal information we already hold about you;
1.1.4 Any personal information provided in customer surveys.
2 What personal information do we collect during the potential or actual purchase of a training event, manual, book, software or training video?
2.1 We collect the following types of personal information:
2.1.1 Your name, date of birth, email address, postal address, telephone or mobile number, bank details;
2.1.2 Details of any contact made with you (either initiated by us or by yourself);
2.1.3 Details about any products and services which you have an interest in as offered during the potential or actual sale
2.1.4 Your marketing preferences (including any requests to opt-out of marketing).
2.2 If you give us personal information about somebody else, such as a colleague, we will assume you have their permission to do so, and their data will also be subject to this Privacy Notice.
In conclusion, rest assured that we will always respect your personal information and any request you make to delete any of your information that is being held by us, will be dealt with at the earliest opportunity.