Privacy Notice

Our contact details
Name: Luke Middleton – GDPR Lead
Phone Number: 07369 210431
E-mail: Luke@mpasuk.com

Our privacy policy is simple…

  • We do not share any personal information we collect with any other
    organisation or individual unless required to verify certain information
    under anti-money laundering regulations.
  • Any information you provide to us is kept completely confidential no
    matter how or why you provided it.
  • Only employees or contractors we specifically employ to complete the
    duties and services we provide to you have access to your information
    and only to perform those duties and services.
    To find details of this policy please read on…

What type of information we have:

We currently collect and process the following information:

  • Your contact details; Name, e-mail address, phone number and physical
    address (phone number and physical address are both optional).
  • Our website may ask for your payment / credit or debit card details in
    order to process a payment for a service you have purchased; this data is
    not stored by our website or shared with any other party.
  • Our website uses cookies to collect information to analyse how many
    individual visitors our website and its pages has. The cookies collect
    information in a way that does not directly identify anyone.
  • We can process card payments over the phone; this data is not stored,
    written down or recorded – it is entered immediately and directly to our
    payment provider.

How we get the information and why we have it:

Most of the personal information we process is provided to us directly by you
for one of the following reasons:

  • For us to contact you in response to your message, query or phone call.
  • To help us provide the service you purchased/booked to you.
  • We take your contact information from the “Contact Us” form, the online
    booking form on our website or an online form e-mailed to you via our
    Dubsado CRM.
  • Or we obtain this information by asking you, when we speak to you over
    the phone, via text message, instant messaging service (i.e. social media)
    or videoconference (ie ZOOM)

We do not receive or obtain personal information indirectly, from any other
source. Only the information you provide to us is the only information we
have.

  • Under the General Data Protection Regulation (GDPR), the lawful bases we
    rely on for processing this information are:
  • Your consent. You can remove your consent at any time. You can do this
    by contacting Luke Middleton on any of the details shown at the top of
    this document.
  • We have a contractual obligation.
  • We have a legal obligation.
  • We have a legitimate interest.

What we do with the information we have:

  • We use the information that you have given us in order to:
  • Provide the service / contractual obligation we have toward you.
  • Send you information about new services we may be able to offer you
    and your business – this will only be tailored and applicable for you and
    your business needs.

 

We do not share this information with anyone outside our organisation.

How we use your information:

How we use your personal data

  • In this Section we have set out:
    (a) the general categories of personal data that we may process;
    (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
    (c) the purposes for which we may process personal data; and
    (d) the legal bases of the processing.
  • We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

  • We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

  • We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include the services and/or products that you have purchased or subscribed to. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

  • We may process information that you post for publication on our website or through our services (“publication data”) – for example if you post questions on our support forums. The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

  • We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.

  • We may process information relating to transactions, including purchases of products and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased products and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

  • We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

  • We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

  • We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

  • We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

  • In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  • With regard to the use, storage and sharing of Google user data through our website, we adhere to the Google API Services User Data Policy including the Limited Use requirements.

    Providing your personal data to others

  • We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
  • We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure
  • In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

    Retaining and deleting personal data

  • This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

  • Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

  • Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

    Security of personal data

  • We will take appropriate technical and organizational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

  • We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

  • The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.

  • Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

  • You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the Internet.

  • You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

    Amendments

  •  We may update this policy from time to time by publishing a new version on our website.

  • You should check this page occasionally to ensure you are happy with any changes to this policy.

  • We may notify you of changes to this policy by email or through private messaging systems in our software or on our website.

    Your rights

  • You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the supply of appropriate evidence of your identity.

  • We may withhold personal information that you request to the extent permitted by law.

  • You may instruct us at any time not to process your personal information for marketing purposes.

  • In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

    Personal data of children

  • Our website and services are targeted at persons over the age of 16.

  • If we have reason to believe that we hold the personal data of a person under that age in our databases, we will delete that personal data.

    Updating information

  • Please let us know if the personal information that we hold about you needs to be corrected or updated.

    About cookies

  • A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

  • Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

  • Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

  • Cookies that we use

  • We use cookies for the following purposes:
    (a) authentication – we use cookies to identify you when you visit our website and as you navigate our website;
    (b) status – we use cookies to help us to determine if you are logged into our website;
    (c) personalization – we use cookies to store information about your preferences and to personalize our website for you;
    (d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
    (e) advertising – we use cookies to help us to display advertisements that will be relevant to you;
    (f) analysis – we use cookies to help us to analyses the use and performance of our website and services; and
    (g) cookie consent – we may use cookies to store your preferences in relation to the use of cookies more generally.

    Cookies used by our service providers

  • Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

  • We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/

    Managing cookies

  • Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
    (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
    (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
    (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
    (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
    (e) (Safari); and
    (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

  • Blocking all cookies will have a negative impact upon the usability of many websites.

  • If you block cookies, you will not be able to use all the features on our website.

Your data protection rights:

Under data protection law, you have rights including:

  • Your right of access – You have the right to ask us for copies of your
    personal information.
  • Your right to rectification – You have the right to ask us to rectify
    information you think is inaccurate. You also have the right to ask us to
    complete information you think is incomplete.
  • Your right to erasure – You have the right to ask us to erase your personal
    information in certain circumstances.
  • Your right to restriction of processing – You have the right to ask us to
    restrict the processing of your information in certain circumstances.
  • Your right to object to processing – You have the right to object to the
    processing of your personal data in certain circumstances.
  • Your right to data portability – You have the right to ask that we transfer
    the information you gave us to another organisation, or to you, in certain
    circumstances.

 

You are not required to pay any charge for exercising your rights. If you make
a request, we have one month to respond to you.

Please contact us at luke@middletonpaservices.com / 01633 441405 if you
wish to make a request.

How to complain:

You can also complain to the ICO if you are unhappy with how we have used
your data.
The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113

Thanks for your email we will be in touch shortly