McBoffin & Company Ltd (“McBoffin & Company”) is the controller and responsible for this website. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users.
We are committed to safeguarding the privacy of our website visitors and service users. In this policy, “we”, “us” and “our” refer to McBoffin & Company Ltd. For more information about us, see Section 11.
2. What personal information we collect about you
Personal information means any information about an individual from which that person can be identified. This
information does not include data where the identity of the person has been removed (anonymous data). The
personal information that we collect, use, process, store and transfer, includes:
- Identity information including your name, the organisation you work for, your title or position you hold in that organisation;
- Contact information including your email address, postal address, and telephone numbers;
- Technical information including information from your visits to our website or applications (including IP address and how you use our website) or in relation to materials and communications we send to you electronically;
- Marketing and communications information including your preferences in receiving marketing materials from us and your communication preferences;
- Information you provide to us for the purposes of attending meetings and events and in response to surveys we send out or that are sent out on our behalf;
- Identification and background information provided by you or collected as part of our business acceptance processes;
- Financial information, including payment-related information;
- Any other information relating to you which you may provide to us.
3. How your personal information is collected
We collect information about you:
- as necessary, in the course of providing our services including as part of our business acceptance processes;
- when you provide it to us, or interact with us directly, including when you request information from us through contact forms on our website or engage with our personnel;
- while monitoring our technology tools and services, including email communications sent to and from us and our website;
- from other sources, including keeping the contact details we already hold for you accurate and up to date by using publicly available sources.
PLEASE DO NOT SUPPLY ANY OTHER PERSON’S PERSONAL DATA TO US WITHOUT THEIR CONSENT.
4. How we use your personal data
We use the personal information that we collect about you, including through your use of our website and in the provision of services by us, in a number of ways:
- to provide you with information requested by you;
- to provide and improve our website, including monitoring its use;
- to provide and improve our services;
- to manage and administer our relationship with you;
- to promote our services, including sending business related updates;
- to fulfil our legal and regulatory obligations;
- for the purposes of recruitment.
We may process data about your use of our website (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your usage. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
We may process your personal data that is provided in the course of the use of our services (“service data”). The service data may include name, address, nationality and other information required to fulfil the service requested or would otherwise make it impossible to provide the service. The source of the service data is you. If you are supplying data on behalf of another person, such as for a business partner, a family member or as an accountant acting on behalf of a client, you must have consent from that person. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract to incorporate a business or purchase a service or product from us.
We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is your request for information or services through your enquiry.
We may process information relating to transactions, including purchases of products and services that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased products and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract to purchase a service or product from us.
We may process information that you provide to us for the purpose of subscribing to our email and SMS notifications (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications about service status and contract updates or changes. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract or to amend or renew a contract when it comes to an end.
We may process information that you provide to us for the purpose of subscribing to our email newsletters (“newsletter data”). The newsletter data may be processed for the purposes of sending you the relevant newsletters. The legal basis for this processing for newsletters is consent.
We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website may generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, and communications with users.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific purposes for which we may process your personal data set out in this Section 4, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. Providing your personal data to others
We may disclose your personal data to:
- our trusted suppliers or subcontractors;
- the Police, Trading Standards, HM Revenue and Customs, or similar official organisations.
As part of service provision to you, we may engage third party suppliers or subcontractors and pass your personal data on to them. This will not include any card payment details. Your McBoffin & Company contact (for example, project manager) will be able to advise which third party (if any) is in possession of your personal data, and will provide that information on your request.
We will disclose your personal data to the Police, Trading Standards, HM Revenue and Customs and other official organisations that have the authority to access our records and are able to prove their identity to us.
In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. If we are required to disclose your personal information to comply with legal or regulatory requirements, we will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.
WE DO NOT SELL OR OTHERWISE MAKE PERSONAL INFORMATION COMMERCIALLY AVAILABLE TO ANY THIRD PARTY, EXCEPT WITH YOUR PRIOR CONSENT.
6. International transfers of your personal data
The level of protection of personal information in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. For example, where our third party service providers process personal information outside the EEA, in the course of providing services to us, our written agreement with them will include appropriate EU standard contractual clauses.
7. How we protect your personal information
We have put in place appropriate security measures to protect your personal information from unauthorised access, use, disclosure, alteration or destruction. We also limit access to your personal information to those employees, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. How long we keep your personal data
We will only retain your personal information for as long as necessary taking into account the requirements of applicable data protection laws and the purpose for which the personal information is collected and used, including for the purposes of satisfying legal, accounting and regulatory requirements to retain the information for a minimum period, good practice and McBoffin & Company’s business purposes.
For example, we will retain your personal data for a minimum period of six years from the end of the last company financial year during which your last payment was received, for your contract to purchase a service or product from us.
Where you have requested quotes through our site, we will keep your request and corresponding quotes for 6 months to enable us to respond to any queries from you, should they arise. Following this period, we will not use the data. We will hash/anonymise the same, and retain it for a further 3 years for internal process improvement purposes.
We have a data retention policy, which clearly sets out how long we keep data for, and for what reasons.
9. Your rights
In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
The right to access – You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.
The right to rectification – You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
The right to erasure – In some circumstances you have the right to erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
The right to restrict processing – In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
The right to object processing – You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
The right to data portability – To the extent that the legal basis for our processing of your personal data is: (i) consent; or (ii) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
The right to complain to a supervisory authority – 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 opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.
The right to withdraw consent – To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above or that you may not be able to make use of the services offered by us.
Even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with meeting our legal and regulatory obligations.
10. Changes to this Policy
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are content with any changes to this policy. We may notify you of changes to this policy by email or through private message on our website.
11. Our details
This website is owned and operated by McBoffin & Company Ltd. We are registered in England and Wales under registration number 11811346, and our registered office is at International House, 36-38 Cornhill, London, EC3V 3NG.
You can contact us:
- by post; the registered office address
- by telephone; the contact number published on our website
- by email, email@example.com
12. Data protection officer
Our data protection officer can be contacted by addressing any correspondence to the “Data Protection Officer” using the contact details in Section 11.