1.1 We, Market Access Systems Limited (see section 13 below), are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
2. Collecting personal information
2.1 We may collect, store and use the following kinds of personal information:
(a) information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
(b) information that you provide to us when registering with our website (including your email address);
(c) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
(d) information that you supply to us through our enquiry form and information relating to the use of the form (including your name, your email address, your telephone number, your postal address and the date and time of your enquiry);
(e) information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use);
(f) information that you post to our website for publication on the internet (including your user name and the content of your posts);
(g) information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication);
(h) any other personal information that you choose to send to us; and
(i) answers to any survey questions which you answer on our website, which may include demographic, financial and behavioural questions.2.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
3. Using personal information
3.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
3.2 We may use your personal information to:
(a) administer our website and business;
(b) personalise our website for you;
(c) refer you to suppliers of goods or services in which you have expressed an interest;
(d) enable suppliers of goods or services in which you have expressed an interest to contact you;
(e) send you non-marketing commercial communications;
(f) send you email notifications that you have specifically requested;
(g) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(h) send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(j) deal with enquiries and complaints made by or about you relating to our website;
(k) keep our website secure and prevent fraud;
(l) verify compliance with the terms and conditions governing the use of our website;
(m) supply to our commercial partners for the purpose of analysis and research in order to allow us to improve our business; and3.3 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
3.4 Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
4. Disclosing personal information
4.1 We may disclose your personal information to any of our employees, officers, professional advisers, agents, suppliers, commercial partners or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal information 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 set out in this policy.
4.3 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
5. International data transfers
5.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we and those listed in section 4.1 operate in order to enable us to use the information in accordance with this policy.
5.2 Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America. We put in place appropriate safeguards in accordance with applicable law to protect data transferred.
5.3 Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
5.4 You expressly agree to the transfers of personal information described in this Section 5.
6. Retaining personal information
6.1 This Section 6 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 information.
6.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
7. Security of personal information
7.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
7.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
7.3 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.4 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
7.5 Where we transfer to another business the information that you supply to us through our enquiry forms, we will do so securely.
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may notify you of changes to this policy by email.Use of our website after a new version of this policy has been posted signifies your acceptance of the new version.
9. Your rights
9.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).9.2 We may withhold personal information that you request to the extent permitted by law.
9.3 You may instruct us at any time not to process your personal information for marketing purposes.
10. Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11. Updating information
11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
12. Data protection registration
12.1 We are registered as a data controller with the UK Information Commissioner’s Office.
12.2 Our data protection registration number is ZA158079
13. Our details
13.1 This website is owned and operated by Market Access Systems Limited.
13.2 We are registered in Jersey, and our principal place of business is at Unit 6, Airport Cargo Centre, L’Avenue de la Commune, St Peter, Jersey, Channel Islands JE3 7BY
13.3 You can contact us by writing to the business address given above, by using our website contact form, by email to firstname.lastname@example.org