Privacy Policy

M Moser Associates Limited (hereafter, “we“, “us” or “our”) is committed to respecting and protecting your privacy.

This privacy policy sets out the basis on which we will process any personal data we collect from you or that you provide to us when we contact you or when you visit our website.

We advise you to read this privacy policy carefully together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are aware of how and why we are using your data. This privacy policy supplements the other policies and notices and does not override them.

For the purposes of the Data Protection Act 1998 and, when it comes into force, the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and all successor legislation to the Data Protection Act 1998 and the GDPR (the “Data Protection Legislation”), the data controller is M Moser Associates Limited (company no. 03897604) with registered offices at 3rd Floor 24 Chiswell Street, London, EC1Y 4YX.

Information we collect from you

Personal data, or personal information, means any information about an individual from which that person can be identified. Personal data does not include data where the identity has been removed (“anonymous data”).

We may collect, use, store and transfer the following data about you:

• Information you give us.
  This is information about you that you give us by filling in forms on our website or by corresponding with us by phone, e-mail, by giving us your business card or otherwise. It also includes information you provide when you request information about our services, subscribe to our newsletter, request marketing to be sent to you, when you report a problem with our site and when you give us feedback. The information you give us may include your name, e-mail address, workplace address phone number (including mobile phone number) and job title.

• Information we collect about you.
  Each time you visit our website, we may automatically collect the following information:
  – Geolocation, including the Internet protocol (IP) address used to connect your computer to the Internet, to detect the location of a visitor and ensure that the content provided is in the correct language (English or Chinese);
  – Information about your visit, including the Internet protocol (IP) address used to connect your computer to the Internet, to provide us with user information such as business name and business address.

• Information we receive from other sources.
  We may receive personal data about you from various third parties including M Moser Associates group companies, marketing companies or other business partners, sub-contractors in technical services, advertising networks, analytics providers and search information providers. We do not collect any special categories of personal data about you. This type of data 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. Please note that where we need to collect personal data by law and you fail to provide that data requested, we may not be able to answer your requests but we will notify you if this is the case

Uses made of your information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal information:

• To carry out our obligations arising from any contracts entered into between you and us or to take steps at your request before entering into any contracts;
• to comply with any legal obligations to which we are subject; or
• there it is necessary for  our or a third party’s legitimate interests but except where such interests are overridden by your interests or fundamental rights and freedoms.

Generally we do not rely on consent as a legal basis for processing your personal information.

Purposes for which we will use your personal data

We have set out below, in a table format, 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 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.

Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

1.

Purpose/ activity
To register and process your request to be contacted on our website

Type of data
Identity and contact details

Lawful basis for processing including basis of legitimate interest
Performance of a contract with you

2.

Purpose/ activity
To manage our relationship with you which will include notifying you about changes to our terms or privacy policy

Type of data
Identity, contact details and marketing preferences

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

3.

Purpose/ activity
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data
Identity, contact details and technical data such as IP address

Lawful basis for processing including basis of legitimate interest:
(a) 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 reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

 4.

Purpose/ activity
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data
Identity, contact details, technical data such as IP address, marketing preferences

Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

5.

Purpose/ activity
To use data analytics to improve our website, marketing, customer relationships and experiences

Type of data
Technical data such as IP address

Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 6.

Purpose/ activity
To make suggestions and recommendations to you about services that may be of interest to you

Type of data
Identity, contact details, usage data and marketing preferences

Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your identity, contact details, usage data, technical data and marketing preferences 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 services, offers or newsletters may be relevant for you.

You will receive marketing communications from us (including newsletters) if you have requested information from us, done business with us or if you provided your details to a third party that was authorised to transfer those details to us under an agreement they have with you and in each case, where 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 company outside M Moser Associates Limited for marketing purposes.

You can ask us to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data you provided to us as a result of a contract we are performing for you or other transactions.

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 be given 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 and that we will do so only where this is required or permitted by law.

Disclosure of your information

We may have to share your personal information with the third parties set out below or any other third parties notified to you, for the purposes set out in paragraph 3 above:

• Professional advisers including lawyers, bankers, auditors and insurers based in the UK.
• Regulators and other authorities who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or mere 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 policy.
• Fraud prevention agencies.
• M Moser Associates group companies
• Contractors / Service Providers

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.

International Transfers

Many of our group companies are based outside the European Economic Area (“EEA”) so their processing of your personal data may involve the transfer of your data outside the 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:

• 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.
• Where applicable, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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.

However, please remember that the transmission of information via the internet is never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

We have put in place procedures to deal with any suspected personal data breach and will notify you or any applicable regulator of a breach where we are legally required to do so.

Retention

We will only retain your personal information for as long as is necessary to carry out the purpose for which it was collected, 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.

Your rights

Under the Data Protection Legislation you may be entitled to the following rights:

Where you have provided your consent to the processing of your personal data for any purpose, you have the right to withdraw such consent at any time by contacting us at St Magnus House, 3 Lower Thames Street, London EC3R 6HD or by email to unsubscribe@mmoser.com.

• You can ask us to rectify any inaccuracies in the personal information that we hold about you.
• To request the erasure of personal information that we hold about you where there is no good reason for us to continue processing it, where you have successfully exercised your right to object to processing, where we may have processed you information unlawfully or where we are required to erase your personal data to comply with local law.
• To object to our processing of your personal data where we are relying on a legitimate interest (or that 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.
• To restrict our processing of your personal data (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.
• To request a copy of your personal data from us in a commonly used and machine-readable format or that we transmit your personal data to another data controller.
• Not to be subject to automated decision-making (including profiling) which has legal or other significant effects on you.
• To access information held about you. 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.

You can exercise any of the above rights at any time by contacting us at St Magnus House, 3 Lower Thames Street, London EC3R 6HD or by submitting an enquiry on our website.

Links to and from our site

Our site may, from time to time, contain links to and from the websites of our partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Changes to your personal data

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.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to St Magnus House, 3 Lower Thames Street, London EC3R 6HD or by submitting an enquiry on our website.

If you have any complaints relating to our privacy policy or our use of your personal data, please contact us at St Magnus House, 3 Lower Thames Street, London EC3R 6HD or by submitting an enquiry on our website.. You also have the right to make a complaint to your local supervisory authority. In the United Kingdom, the Information Commissioner’s Office (ICO), is the supervisory authority for data protection issues. Further information can be found at www.ico.org.uk.