MMG respects your privacyand is committed to protecting your personal data.
1. OUR AIMS, CHANGES, CAPACITY and 3rdPARTY WEBSITES
This privacypolicyaims to give you information on how MMG collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service. This website is not intended for children and we do not knowingly collect data relating to children.
We keep our privacypolicyunder regular review. 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.
MMG BUSINESS LONDON Ltd (trading as MMG Models) the controller and responsible for your personal data (collectively referred to as ”MMG”, “we”, “us” or “our” in this privacypolicy). If you have any questions about this policy please contact us using details provided on this website. 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
). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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 privacystatements. When you leave our website, we encourage you to read the privacypolicyof every website you visit.2. DATA COLLECTED, FAILUR TO PROVIDE DATA AND EXCLUSIONS 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 as follows:
•Identity Dataincludes first name, maiden name, last name, username or similar identifier, marital status.
•Contact Dataincludes billing address, delivery address, email address and telephone numbers.
•Financial Dataincludes bank account and payment card details.
•Transaction Dataincludes details about payments to and from you and other details of products and services you have purchased from us.
•Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data
such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will notdirectly 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 treat the combined data as personal data which will be used in accordance with this privacypolicy.
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 product or service you have with us but we will notify you if this is the case at the time.
We do not collect any Special Categories of Personal Dataabout 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.3. HOW WE COLLECT YOUR DATA
We use different methods to collect data from and about you including throughdirect 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:
•apply for our products or services;
•give us feedback or contact us..
•Third parties or publicly available sources.We will receive personal data about you from various third parties 4. ALLOWED USE, CONSENT, PURPSOSE AND MARKETING 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 obligation.
Generally, we do not rely on consent
as a legal basis for processing your personal data although we will get your consent before sending third party 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.
We have set out below, in a table format, a description of all the ways we plan to use your personal data
. 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.
Purposes are as follows:
- To register you as a new customer (Identity & Contact) when performing contracts with you;
- To process and deliver orders including fees and collection of sums due (Identity, Contact, Financial, Transaction and Marketing Communications) when performing contracts and during recovery of sums;
- To keep you informed on changes to our policy, asking for a survey or a review (Identity, Contact and Marketing) when performing contract with you and as required by law.;
- To protect our business and conduct administrative tasks including but not limited to system maintenance, support reporting data analysis (Identity and Contact) necessary for running our business, provision of IT services, network security, fraud prevention and other legal obligations;
- To provide you with data on our website and advertise in an effective way (Identity, Contract, Usage and Marketing Communications) in order to understand how our clients use our services and to grow our business.
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.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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, 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 goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages 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 product/service purchase.5. HOW WE DISCOLOSE YOUR DATA We may share your personal data
with the parties set out below for the purposes set out in the table above. This includes Internal Third Parties and External Third Parties. 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 privacypolicy.
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. DATA TRANSFERS
We share your personal data within the MMG BUSINESS LONDON Ltd Group. This will involve transferring your data outside the European Economic Area (EEA).
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:
Where we use providers based in the US, we may transfer data to them if they are part of the PrivacyShield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US PrivacyShield
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 European Commission: Adequacy of the protection of personal data in non-EU countries
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 European Commission: Model contracts for the transfer of personal data to third countries
.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
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements. 9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. See Data Subject Rights Under the GDPR. If you wish to exercise any of the rights set out above, please contact us. 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 could refuse to comply with your request in these circumstances.
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.10. LEGAL BASIS AND THIRD PARTIES
Legitimate Interestmeans the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 Contractmeans 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 obligationmeans processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
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.
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.
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:
•If you want us to establish the data’s accuracy.
•Where our use of the data is unlawful but you do not want us to erase it.
•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.
•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. 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.
Internal third parties includes other companies in the MMG BUSINESS LONDON Ltd group (trading as MMG Models Ltd)
External third parties
Includes Service providers; Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services; HM Revenue & Customs, regulators and other authorities