Introduction

Welcome to the MMS360 privacy notice.

MMS360 respects your privacy and is committed to protecting your personal data. This privacy notice
will explain how we look after your personal data when you visit our website (regardless of where you
visit it from) or when you provide personal data to us via other means (such as via e-mail, over the
telephone etc.) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so that you can easily click through to the specific
areas set out below. Alternatively, you can download a pdf version of the policy here.

Please also refer to the Glossary at the end of the Policy, if there is any terminology used in this privacy
notice that you are unfamiliar with or that you don’t fully understand.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW YOUR PERSONAL DATA IS COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. HOW WE DISCLOSE YOUR PERSONAL DATA
6. WHEN WE TRANSER YOUR DATA OVERSEAS
7. HOW WE SECURE YOUR DATA
8. HOW LONG WE RETAIN YOUR DATA FOR
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how MMS360 collects and processes your personal
data, including any data you may provide through this website or via any other means (such as via e-
mail, over the telephone etc.) when you engage us to provide you with professional services.
This website is not intended for children we do not knowingly collect any data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing
notice we may provide on specific occasions when we are collecting or processing personal data about
you so that you are fully aware of how and why we are using your data. This privacy notice supplements
the other notices and is not intended to override them.

Controller

MMS360 Limited is the controller and responsible for your personal data (collectively referred to as
‘MMS360’, ‘we’, ‘us’ or ‘our’ in this privacy notice).

We have appointed a data privacy manager 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 the data privacy manager using the details set out below.

Contact details

Our full details are:
Full name of legal entity: MMS360 Ltd
Name or title of data privacy manager: Simon Rosser
Email address: simon@mms360.co.uk
Postal address: MMS360, Unit 4 Park Court, Pyford Road, West Byfleet, KT14 6SD.
Telephone number: 01932 345519
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the
UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the
chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 08/02/2021 and historic versions can be obtained by contacting us.
It is important the personal data we hold about you is accurate and current. Please keep us informed if
any of the details you provide to us should change, during the course of your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links
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.

2. 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).
We may collect, use, store and transfer different kinds of personal data about you which we have
grouped together follows:

  •  Identity Data
    This includes data relating specifically to your identity, such as your first name, maiden name,
    last name, marital status, title, date of birth and gender.
  • Contact Data
    This includes data relating to how you may be contacted, such as your address, email address,
    telephone numbers and next of kin details.
  • Financial Data
    This include data relating to your means and methods of payment, such as your bank account
    and payment card details.
  • Transaction Data
    This includes data relating to the transactions you have carried out with us, such as details about
    payments to and from you and other details of professional services you have purchased from us
    as well as delegate costs etc.
  • Technical Data
    This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data
    This includes information about how you use our website, products and services.
  • Marketing and Communications Data
    This includes your preferences in relation to whether or not you want to receive marketing from
    us and our third parties and also your communication preferences.

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
will treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Categories of Personal Data

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.
We may from time to time ask you to provide the following special categories of personal data:

  •  Details about your health.

We collect and process the above data only where it is strictly necessary to do so in order to
accommodate any requirements. Furthermore, we will only collect and process the above special
categories of sensitive personal data where you have provided us with your explicit consent to do so.
You are not under any obligation to consent to us processing your sensitive personal data. However,
without your consent, we won’t be able to make the necessary arrangements to accommodate your
needs or to provide the services that you have engaged us to provide. As a result, if you do not provide
your consent, we will be unable take either of these steps.
If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you 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.
In other words, where we require details from you in order to provide you with services that you have
chosen to engage us to provide, if you do not provide us with the necessary details then we will not be
able to provide the services in question.

3. How your personal data is collected?

We use different methods to collect data from and about you including through:

  • Direct interactions
    You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding
    with us by post, phone, email or otherwise. This includes personal data you provide when you:
    o Engage us to provide services;
    o request marketing to be sent to you; or
    o provide us with feedback.
  •  Third parties
    We may receive personal data about you from various third parties as set out below:
    o Technical Data from the following parties:
    – analytics providers such as Google based outside the EU;
    o Identity and Contact Data from the following parties:
    – information providers such as market researchers and consultants based inside
    the EU; and

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your
personal data in the following circumstances:

  •  Where we need to perform the contract we are about to enter into or have entered into with you.
  •  Where it is necessary for our legitimate interests (or those of a third party) and your interests
    and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

 

Generally we do not rely on consent as a legal basis for processing your personal data other than in
relation to sending direct marketing communications to you via email or text message. You have the
right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data,
and which of the legal bases we rely on to do so. We have also identified what our legitimate interests
are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific
purpose for which we are using your data. Please contact us if you need details about the specific legal
ground we are relying on to process your personal data where more than one ground has been set out in
the table below.

Marketing

We strive to provide you with choices about certain personal data uses, particularly marketing and
advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think
you may want or need, or what may be of interest to you. This is how we decide which professional
services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or
purchased services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for
marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-
out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data that you
have provided to us as a result of an engagement to provide you with professional services or other such
transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible
with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the
legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance
with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the
table in paragraph 4 above.

  •  External Third Parties as set out in the Glossary.
  •  Third parties to whom we may choose to sell, transfer, or merge parts of our business or our
    assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change
    happens to our business, then the new owners may use your personal data in the same way as
    set out in 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.

6. International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

7. Data security

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 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 put in place procedures 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.

8. Data retention

How long will you use my 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 addition to the above, by law we have to keep basic information about our customers (including
Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for
tax purposes.
Further information regarding our retention periods is available by contacting us.
In some circumstances you can ask us to delete your data: see Request erasure below for further
information.
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.

 

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal
data. Please click on the links below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your
right to access your personal data (or to exercise any of your other rights). This is a security measure to
ensure that personal data is not disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a
month if your request is particularly complex or you have made a number of requests. In this case, we
will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

  • Legitimate Interest
    means the interest of our business in conducting and managing our business to enable us to give
    you the best service and the best and most secure experience. We make sure we consider and
    balance any potential impact on you (both positive and negative) and your rights before we
    process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
  • Performance of Contract
    means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation
    means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to

THIRD PARTIES

  • External Third Parties
    o Service providers acting as processors based in the United Kingdom who provide IT and
    system administration services.
    o Professional advisers acting as processors or joint controllers including lawyers,
    bankers, auditors and insurers based in the United Kingdom who provide consultancy,
    banking, legal, insurance and accounting services.
    o HM Revenue & Customs, regulators and other authorities acting as processors or joint
    controllers based in the United Kingdom who require reporting of processing activities
    in certain circumstances.

YOUR LEGAL RIGHTS
You have the right to:

  • Request access
    to your personal data (commonly known as a "data subject access request"). This enables you to
    receive a copy of the personal data we hold about you and to check that we are lawfully
    processing it.
  • Request correction
    of the personal data that we hold about you. This enables you to have any incomplete or
    inaccurate data we hold about you corrected, though we may need to verify the accuracy of the
    new data you provide to us.
  • Request erasure
    of your personal data. This enables you to ask us to delete or remove personal data where there
    is no good reason for us continuing to process it. You also have the right to ask us to delete or
    remove your personal data where you have successfully exercised your right to object to
    processing (see below), where we may have processed your information unlawfully or where we
    are required to erase your personal data to comply with local law. Note, however, that we may
    not always be able to comply with your request of erasure for specific legal reasons which will
    be notified to you, if applicable, at the time of your request.
  •  Object to processing
    of your personal data where we are relying on a legitimate interest (or those of a third party)
    and there is something about your particular situation which makes you want to object to
    processing on this ground as you feel it impacts on your fundamental rights and freedoms. You
    also have the right to object where we are processing your personal data for direct marketing
    purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to
    process your information which override your rights and freedoms.
  • Request restriction of processing
    of your personal data. This enables you to ask us to suspend the processing of your personal data
    in the following scenarios:
    o if you want us to establish the data's accuracy;
    o where our use of the data is unlawful but you do not want us to erase it;
    o where you need us to hold the data even if we no longer require it as you need it to
    establish, exercise or defend legal claims; or
    o you have objected to our use of your data but we need to verify whether we have
    overriding legitimate grounds to use it.
  • Request the transfer
    of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time
    where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.