MAVIN INFORMATICS LIMITED
|2||Collection of Personal Data|
|3||How we collect your Personal Data|
|5||Using Your Personal Data|
|6||Disclosure of Your Personal Data|
|9||Your Legal Rights|
1. IMPORTANT INFORMATION
It is important that you read this privacy notice so that you are fully aware of how and why we are using your data. This privacy notice supplements the other policies and is not intended to override them.
- 1.1 Data Controller
The Products and/or Services (websites and web Services: mi-SOS.org® and mi-PET-SOS.org®), are owned by Mavin Informatics Limited and operated by Mistura Informatics Ltd via Service Level Agreement (‘we’/’us’/’our’). The company is located in the UK and therefore adhere to any UK law. Mavin Informatics is a limited company (trading with: mi-SOS.org® and mi-PET-SOS.org®), and is registered in England and Wales under the following details:
Company Name: Mavin Informatics Limited
Company Registration Number: 12276986
VAT Number: GB 341 266 029
Registered Office: 1 GEPs Place
For the purposes of the Data Protection Act 1998, we are the “data controller” (i.e. the company who is responsible for and controls the processing of, your personal data).
- 1.2 Data Protection Officer:
Note: 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 (www.ico.org.uk (http://www.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.
- 1.3 Changes to this Policy:
This version was created on 2nd December 2019 and was updated on the 1st October 2020. It is important that the personal data we hold about you is accurate and current so keep us informed if your personal data changes during your relationship with us. Consequences of inaccurate or incomplete data are outlined in the Mavin Informatics Limited Terms and Conditions of Use and Service, available from mi-SOS.org® and mi-PET-SOS.org®.
- 1.4 Third-Party Links:
Please acknowledge third party links for our Product and/or Services below:
- Our websites may include links to third-party websites, plug-ins and supplementary 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 websites, we encourage you to read the privacy notice of every website you visit.
- Our web-service application (mi-SOS.org®) may include links to the NHS organisations only to transfer essential data and enable quicker time to treatment for you.
- Our web-service application (mi-PET-SOS.org®) may include links to Vet practices only to transfer essential data and enable quicker time to treatment for pets.
2. COLLECTION OF PERSONAL DATA
- 2.1 Personal Data:
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).
- 2.2 Types of Personal Data we Collect:
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes your email address and billing address, delivery address, and telephone numbers.
- Profile Data includes your username and password, entries that you make on our decision aid application, purchases or orders made by you for applications, your interests, preferences, feedback and survey responses.
- Technical Data includes your internet service provider name, operating system and type of web browser you used, internet protocol (IP) address, your login data, time zone setting and location, browser plug-in types and versions, and other technology on the devices you use to access our Products and/or Services.
- Usage Data includes aggregate and user-specific information on which pages you view, content searched for, page response times, length of visits to certain pages, page interaction information.
- Financial Data includes any payment information and financial details you provide in order to use for our Products and/or Services.
- Recruitment Data includes special category data: gender, age, ethnic origin and health information connected with disability.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences. We do not share your data with third parties.
- We also collect, use and share Aggregated Data including statistical or demographic data. 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 or application feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.
- 2.3 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 (for example, to provide you with goods or Services). In this case, we may have to cancel a Products and/or Service you have with us, but we will notify you if this is the case at the time. For full details see the Mavin Informatics Limited: Terms and Conditions of Use and Service.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including:
- 3.1 Direct interactions:
You may give us your Identity, Contact and Financial Data by completing forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our Products and/or Services; register for and create an account on our Products and/or Services including web applications; sign up for an event run by us; subscribe to our service or publications; engage with interactive features of our Products and/or Services, including chat, groups and networks; request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback; to report a problem with our site; apply for a role through Recruitment; share the information e.g. a direct message through a social media platform.
- 3.2 Automated technologies or interactions:
- 3.3 Third parties or publicly available sources:
We may receive personal data about you from various third parties and public sources as set out below in section 3.4 and 3.5. (For sharing of data with third parties please see paragraph 5.1 and paragraph 6).
- 3.4 Technical Data:
Technical data is received from the following parties:
(a) analytics providers such as Google Analytics based outside the EU;
(b) advertising networks such as Facebook and Instagram based outside the EU;
(c) search information providers such as Google based outside the EU.
- 3.5 Contact Data:
Contact, Financial and Transaction Data from providers of technical, payment and delivery Services such as Paypal.
Contact Data and Identity Data from publicly availably sources such as Companies House.
4. USE OF COOKES
- 4.1 What are Cookies?
- 4.2 How to Block Cookies:
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Further information on deleting or controlling cookies is available at: www.AboutCookies.org.
5. USING 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 that we are about to enter into or have entered into with you.
- Where it is necessary for our or your legitimate interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- 5.1 Consent:
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to aspects of:
- Your health data
- 5.2 Consent to Data Processing and Storage:
In this instance, by registering an account and inputting data into your profile, you confirm your agreement to both processing, storing your personal data i.e. consent that you wish to submit your personal information to our Products and/or Services (including websites and web Services: mi-SOS.org® and mi-PET-SOS.org®).
- 5.3 Consent to Data Sharing:
As you control what information you make visible on your profile, then you are consenting to the vital information you would like to share with members of the public or emergency services via scanning your QR code (your data). You are consenting to share your information in two ways by either:
a. not confirming to make information “invisible”
b. populating fields within your profile rather than leaving them blank
Consenting to share your information means you would like to share your data in an emergency with members of the public or emergency services via scanning your QR code (your data).
- 5.4 Implied Consent:
Note: In addition to Consenting to data sharing above, wearing a QR code Product means you demonstrate your consent to be scanned by anyone in an emergency in order to help you, as each Product states: I.C.E.* SCAN ME (* In Case of Emergency). This is considered as “implied consent”.
- 5.5 Withdrawing Consent:
You have the right to withdraw your consent at any time. You withdraw your consent by the following methods:
- Withdrawing Implied Consent: Not wearing your QR product.
- Withdrawing Consent for Data Sharing: Logging onto your account to our Products and/or Services via your user account and either;
- complete the checkbox to make information invisible;
- removing data from your profile fields to leave them blank.
- Withdrawing consent to data processing and storage:
- removing data from profile fields to leave them blank;
- cancelling subscription immediately.
- 5.6 Data Security:
- Protection of your data is of paramount importance. Whilst we strive to make our Products and/or Services as secure as possible, there is the possibility of the loss of your wearable with QR code. Should this happen, you must secure your data by logging onto your account to our Products and/or Services via your user account and disable your QR code immediately when another code will be generated for you.
- 5.7 Purposes of Use of Personal Data:
We have set out below, 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: We may process your personal data for more than one lawful ground depending on the special purpose for which we are using your data. Please contact us if you need details about the special legal ground, we are relying on to process your personal data where more than one ground has been set out below.
Purpose and/or activity for processing data:
a. To register you as a new member or registered user
b. To process and deliver your orders on this website, for events and Products, including:
1. Manage payments, fees and charges,
2. Collect and recover money owed to us,
3. Direct Debit credit reference checking.
NOTE: This information will be processed by PayPal, iZettle, Worldpay and GB Group for e-commerce purposes
c. To carry out our obligations arising from registering as a website or application user including notifying you of Products and/or Services, entering you into our database, notifying you about changes to your registration and other purposes connected with your registration
d. To notify specified NHS organisations and or employees of new user members where the user has consented to do so
e. To manage our relationship with you which will include:
2. Asking you to leave a review or take a survey including sending an email asking you to rate your experience of using our applications,
3. Providing you with information for and asking for feedback about an event you registered for on our site
f. To enable you to plan, record and enter information and records on our applications or website, partake in a prize draw, competition or complete a survey
g. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and to ensure that content from our site is presented in the most effective manner on your computer
h. To deliver relevant website content to you and measure or understand the effectiveness of the information we serve to you
i. To use data analytics to improve our website, Products and/or Services, marketing, customer relationships and experiences
j. To make suggestions and recommendations to you about Products and/or Services that may be of interest to you
k. To process your application for a job within Mistura
Types of data processed:
c. Profiled. Usage
e. Marketing and Communications
i. Special Data
Lawful basis for data processing including the basis of legitimate interest:
a. Performance of a contract with you
b. Necessary for our legitimate interests (to recover debts due to us)
c. Necessary for our and your legitimate interests (to promote the shared decision aid)
d. Necessary to comply with a legal obligation
e. Necessary for our legitimate interests (to keep our records updated and to study how customers use our Product/Services)
f. Necessary for our legitimate interests (to study how customers use our Product/Services, to develop them and grow our business)
g. Necessary for our legitimate interests (for running our business, provision of administration and IT Services, network security, to prevent fraud and in the context of a business re-organisation or group restructuring exercise)
h. Necessary for our legitimate interests (to study how customers use our Product/Services, to develop them, to grow our business and to inform our marketing strategy)
i. Necessary for our legitimate interests (to define types of customers for our Product and Services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
j. Necessary for our legitimate interests (to grow our business)
k. Compliance with legal obligations associated with employment
l. Your specific consent
- 5.8. Marketing:
We strive to provide you with choices regarding certain personal data uses, particularly around the marketing of Mavin Informatics Ltd Product and/or Services only. Within your user account, you can view and make certain decisions about your personal data use.
- Promotional Offers and Newsletters 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 Products and/or Services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us only if you have requested information from us, registered on our websites or purchased our Product and/or Services from us within the last 24 months and, in each case, you have not opted out of receiving that marketing.
- Third-Party Marketing
We do not share your personal data with any company outside the Mavin Informatics Ltd company for marketing purposes.
- Opting Out
You can ask us to stop sending you marketing messages at any time by logging into your account relating to our Product and/or Services, and either by;
- checking or unchecking relevant boxes to adjust your marketing preferences or 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 provided to us as a result of a Products and/or Service purchase including registration for our Product and/or Services, please see paragraph 5 above.
- 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 any unrelated purpose, we will notify you first and we will explain the legal basis that allows us to do so. 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.
- Interactive Services
There are parts of our website which permit registered users to post user-generated content e.g. Feedback. All content posted in such areas must comply with our terms and conditions. We ask you not to enter content, which contains personal information.
6. DISCLOSURE OF YOUR PERSONAL DATA
When you contribute content to public or shared areas of our Product and/or Services, you will be credited as the contributor using your username. This accreditation will appear on the service and will, therefore, be visible to other users. The default setting for the user ID is your first name and surname. You can change these fields is by logging in to your profile.
We may have to share your personal data with the parties identified below for the purposes set out in paragraph 5 above.
- External Third Parties e.g. NHS as set out in the Glossary.
- Paypal for the purposes of delivering e-commerce Services as specified in paragraph 5 above.
- 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 or for marketing and only permit them to process your personal data for specified purposes in delivering the contract with you and in accordance with our instructions.
7. SECURITY MEASURES
- 7.1 Our Responsibilities:
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.
- 7.2 Your Responsibilities:
Where you have access to a secure area of our Product and/or Services, you are responsible for keeping your login details and password(s) confidential and protected. You also are required to verify your email address and so you are also responsible for keeping your email address login details and password(s) confidential and protected.
We ask you not to share your password with anyone. You can change your password at any time by logging in.
We accept no responsibility or liability if a third party obtains and uses your ID or password. Please see Mavin Informatics Ltd: Terms and Conditions of Use (v1.1) for further information.
Note: You must tell us immediately if you believe someone may have access to or use of this information. 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.
We will keep basic information about our members and registered users (including Contact, Identity, Financial and Transaction Data) for two years after they cease being members or subscribers to our Product and/or Services. In some circumstances you can ask us to delete your data: see below paragraph 9 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.
- 9.1 Your 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. This is where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that 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 lawful 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;
(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 Product and/or Services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact our data protection officer at: firstname.lastname@example.org or use the contact details set out at the beginning of this policy.
- 9.2 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.
- 9.3 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.
- 9.4 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.
- 10.1 Lawful Basis:
Legitimate Interest: means the interest of our business in conducting and managing our business to enable us to give you the best Products and/or 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 special 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.
- 10.2 External Third Parties:
Legitimate third parties we may share personal data with includes:
- NHS to facilitate your care and to speed up time to treatment
- Vet Practices to facilitate your pets care and speed up time to treatment
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances
- Survey Monkey, based in the US, who provide Services in connection with surveying members
- PAYPAL for the purposes of delivering e-commerce Services.
Social media platforms we may share data with to allow us to target advertising that is relevant to you: