WHO WE ARE
Miramar Communications Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
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.
WHEN DO WE COLLECT PERSONAL DATA AND WHAT PERSONAL DATA DO WE COLLECT
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 and store the following personal data about you, which we have grouped into the following categories:
- If you fill in forms on our website, we will collect your contact details and any other information you provide in the form.
- If you contact us by any other means (e.g. email or telephone), we may keep a record of that contact and the information you provide us with at that time.
- If you ask to be added to our marketing database, we will collect your name, the name of your company/organisation (if any), email address and your preferences as to the types of marketing information you would like to receive from us.
- If you engage us to provide you with any of our services, we will collect your billing address, email address and telephone numbers. We will also collect transaction details about payments to and from you and other details of services you have purchased from us.
- If your personal data is on publicly available sources (such as LinkedIn and Companies House) then we may collect your personal data that is available on these sources.
- If you submit job applications to us or if we receive your job application via a recruitment company, we will collect your contact details and any other information you provide in the application.
- If we meet you at a networking event or trade show, we will collect your contact details and any other information you provide to us at these events.
- If your personal data is available from data suppliers, then we may obtain your personal data from data suppliers, provided that the personal data supplier complies with the relevant privacy laws.
OTHER INFORMATION COLLECTED VIA OUR WEBSITE AND COOKIES
As you interact with our website, we may automatically collect information about your website usage such as information about your internet protocol (IP) address, equipment, browsing actions and patterns. We collect this information by using cookies, server logs and other similar technologies.
Our website uses a limited number of cookies, namely:
- Cookies required by Google Analytics in order to measure your website usage and improve the experience for our visitors on an ongoing basis. These cookies collect the information about your website usage, namely what pages you visit, how long you stay on each section of the website, and what links you click on.
- Cookies required by CANDDi, in order to identify visitors each time that they return to our site and relate tracking to a single Session. CANDDi can also place some CAN_Store_xxx cookies. These are temporary cookies which CANDDi uses to ensure that the data which has been captured is recorded and transmitted to the CANDDi servers. These cookies are deleted after a positive response is received from the CANDDi tracking servers.
We may use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
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 interest (or those of a third party) and your interest and fundamental rights do not override those rights.
- Where we need to comply with a legal or regulatory obligation.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We will collect your personal data for the following purposes:
- To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) on the basis that it is necessary to comply with a legal obligation and that we have a legitimate interest to do so (for running our business, provision of administration and IT services, network security and to prevent fraud).
- To deliver relevant website content and send marketing information to you and measure or understand the effectiveness of these activities. We will do so on the basis that you have consented to us processing your personal data in this way or on the basis that we have a legitimate interest to do so (to grow our business, develop our products/services, to study how customers use our products/services and to keep our marketing strategy current). You can always stop receiving marketing information from us at any time as these communications provide easy ways to unsubscribe or update your preferences.
- To process and deliver your order including managing payments, fees and charges and collecting and recovering money owed to us on the basis of our performance of our contract with you.
- To process job applications and CVs submitted to us on the basis that we have a legitimate interests to do so (to fill vacancies and to grow our business). If you would like further details on how we treat personal information submitted to use via job applications and CVs, then please contact us on firstname.lastname@example.org to request these details.
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 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.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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.
Some of the sub-contractors we engage may store your personal data outside the European Economic Area. In such circumstance we will ensure that any of your personal data that may be transferred to sub-contractors in third countries meet the adequacy requirements of the European Commission or as are required under the privacy laws applicable in the UK.
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.
WHO DO WE SHARE YOUR PERSONAL DATA WITH
We may disclose your personal data to third parties as follows:
- If we are under a duty to disclose or share it in order to comply with any legal obligation (for example our auditors, our insurers and HMRC).
- With sub-contractors who we engage to assist us in providing our services on the basis that we have a legitimate interest to do so and then only if they have agreed with us that they will only process your personal data on our instructions and that they will keep it confidential and secure.
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.
The table below sets out further details:
|Circumstances in which personal data was provided||How long do we keep it?|
|When you contact us via our website.||Until you request the information to be removed or we refresh our database to suppress dormant entries (typically on an annual basis)|
|When you contact us by any other means (e.g. email or telephone) which does not lead to a contractual relationship.||Until you request the information to be removed or we refresh our database to suppress dormant entries (typically on an annual basis)|
|When you enquire about job vacancies or submit a job application.||6 months|
|When we receive your information from publicly available sources or when you are added to our marketing database.||Until you request the information to be removed or we refresh our database to suppress dormant entries (typically on an annual basis).|
|When we obtain your information from data suppliers.||Until you request the information to be removed or we refresh our database to suppress dormant entries (typically on an annual basis).|
|When we receive your information at a networking event or at a trade show.||Until you request the information to be removed or until we refresh our database to suppress dormant entries (typically on an annual basis).|
|When we enter into a contract with you.||1 year after the expiry or termination of the contract or as soon the personal data is no longer needed.|
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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.
Post: Kestrel House, Howbery Park, Wallingford, United Kingdom, OX10 8BA
Telephone: 01491 825 288
You have the right to complain to the Information Commissioner about the way in which we collect and use your personal data: www.ico.org.uk/concerns or telephone 0303 123 1113.