Please read this privacy notice (“Privacy Notice”) carefully as it describes our collection, use, disclosure, retention and protection of your personal information. This Privacy Notice applies to any website, application or service which references this Privacy Notice. Where you provide us with your personal information in any of the ways described below, you agree that we may collect, store and use it: (a) in order to perform our contractual obligations to you; (b) based on our legitimate interests for processing (i.e. for internal administrative purposes, data analytics, direct marketing, maintaining automated back-up systems or for the detection or prevention of crime); or (c) based on your consent, which you may withdraw at any time, as described in this Privacy Notice.
Your personal data is data which by itself or with other data available to Miles 33 can be used by us to identify you.
This Privacy Notice applies to all products, applications and services offered by Miles 33 Group Limited (a company incorporated in England with company registration number 02873904 and whose registered office address is at Miles House, Easthampstead Road, Bracknell, Berkshire, RG12 1NJ, UK) and its affiliates
If you are based within the EEA (which means all the EU countries plus Norway, Iceland and Liechtenstein) or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:
If you request a copy of your information you may be required to pay a statutory fee.
If we hold any information about you which is incorrect or if there are any changes to your details, please let us know by so that we can keep our records accurate and up to date.
If you withdraw your consent to the use of your personal information for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our website, applications, and services.
We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes or as otherwise permitted by applicable laws and regulations.
Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).
To the extent permissible under applicable law, we collect information about you and any other party whose details you provide to us when you:
We may also collect your information where you only partially complete and/or abandon any information inputted into our website and/or other online forms and may use this information to contact you to remind you to complete any outstanding information.
We also collect information from your devices (including mobile devices) and applications you or your users use to access and use any of our websites, applications or services (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your web log information).
We may do this using cookies or similar technologies (as described in section 11 below).
We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from credit agencies, search information providers or public sources (e.g. for customer due diligence purposes), but in each case as permitted by applicable laws.
If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Notice.
To the extent permissible under applicable law, we use your information to:
To the extent permitted by applicable law, we retain information about you after the closure of your account or if you decide not to proceed. This information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.
Our website, applications (including mobile applications) and services may contain technology that enables us to:
You can manage your privacy settings within your browser or our applications and services (where applicable).
We may monitor and record our communications with you, including e-mails and phone conversations.
Information which we collect may then be used for quality assurance, to record details about our website, applications and services you order from us or ask us about, and in order to meet our legal and regulatory obligations generally.
We may obtain information through mobile applications that you or your users install on their mobile devices to access and use our website, applications or services.
Mobile applications may provide us with information related to the use of our applications and services accessed using that mobile application. We may use such information to provide and improve the mobile application or our own application or services. For example, activity undertaken within a mobile application may be logged.
You can configure our mobile application’s privacy settings on your device but this may affect the performance of that mobile application and the way it interacts with our applications and services.
We may use information generated and stored during your use of our services for our legitimate business interests to enable us to give you the best service and/or solutions and the best experience.
These purposes include to:
You have the right to object to processing based on our legitimate interests, and if you wish to do so, please contact us at email@example.com to discuss this further. If you object, this may affect our ability to provide certain services and/or solutions for your benefit.
We may share your information with:
We may share non-personally identifiable information about the use of our website, applications, products or services publicly or with third parties but this will not include information that can be used to identify you.
From time to time, we may use your information to contact you with details about our applications, products and services which we feel may be of interest to you. We may wish to contact you for this purpose by telephone, post, SMS or email. You have the right at any time to stop us from contacting you for marketing purposes. You may also request at any time that we do not share your information with third parties. If you wish to exercise these rights you can do so by selecting your contact preferences at the point where you provide us with your information on our websites, applications or services, using any preference centres we give you access to or by sending us an email to firstname.lastname@example.org. You can also unsubscribe from any email marketing using the links provided in the emails we send to you.
Where you respond to communications we post on third-party platforms (such as Facebook, Google and Twitter), we may also share your information with those third parties in order to serve targeted
advertising/content to you via the relevant third-party platform based on your profile/interests. Your
information is used by the third-party platform provider to identify your account and serve advertisements to you. You can control what advertisements you receive via the privacy settings on the relevant provider’s platform and you should consult the third party’s help/support centre for more information.
We may change this Privacy Notice from time to time. However, we will not reduce your rights under this Privacy Notice. We will always update this Privacy Notice on our website, so please try to read it when you visit the website.
We will keep your information secure by taking appropriate technical and organisational measures to prevent unauthorised or unlawful processing and accidental loss, destruction or damage. We will do our best to protect your personal information but we cannot guarantee the security of your information which is transmitted to our website, applications or services or to other website, applications and services via an internet or similar connection. If we have given you (or you have chosen) a password to access certain areas of our websites, applications or services please keep this password safe.
If you believe your account has been compromised, please contact us at email@example.com.
Personal information in the European Union is protected by data protection laws but other countries do not necessarily protect your personal information in the same way. We may use service providers based outside of the EEA to help us provide our email, website, applications and services to you (for example, platform and payment providers who help us deliver our applications and services, or advertising or execute your payments) and this means that we may transfer your information to service providers outside the EEA for the purpose of providing our applications, advertising and services to you.
We take steps to ensure that where your information is transferred outside of the EEA by our service
providers and hosting providers, appropriate measures and controls are in place to protect that information in accordance with applicable data protection laws and regulations. For example, we may share information with our group companies or affiliates based outside the EEA for the purposes envisaged by this Privacy Notice. All Miles 33 group companies are subject to Miles 33 group data protection policies designed to protect data in accordance with EU data protection laws. In each case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.
By using our website, products or services or by interacting with us in the ways described in this Privacy
Notice, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Notice. If you do not want your information to be transferred outside the EEA you should not use our website, applications or services or contact us at firstname.lastname@example.org.
If you follow a link from our website, application or service to another site or service, this Privacy Notice will no longer apply. We are not responsible for the information handling practices of third party sites or services and we encourage you to read the privacy notices appearing on those sites or services.
Our websites, applications or services may enable you to share information with social media sites or use social media sites to create your account or to connect your social media account. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third party social media account(s) to manage what personal information you enable us to access from that account.
Our cookies may be session cookies (temporary cookies that identify and track users within our websites, applications or services which are deleted when you close your browser or leave your session in the application or service) or persistent cookies (cookies which enable our websites, applications or services to “remember” who you are and to remember your preferences within our websites, applications or services and which will stay on your computer or device after you close your browser or leave your session in the application or service).
We use the following different types of cookies:
These are cookies which are needed for our websites, applications or services to function properly, for example, these cookies allow you to access secure areas of our website or to remember what you have put into your shopping basket.
These cookies allow our websites, applications and services to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
We keep a record of traffic data which is logged automatically by our servers, such as your Internet Protocol (IP) address, device information, the website that you visited before ours and the website you visit after leaving our site. We also collect some site, application and service statistics such as access rates, page hits and page views. We are not able to identify any individual from traffic data or site statistics.
You may be able to configure your browser or our website, application or service to restrict cookies or block all cookies if you wish, however if you disable cookies you may find this affects your ability to use certain parts of our website, applications or services. For more information about cookies and instructions on how to adjust your browser settings to accept, delete or reject cookies, see the www.allaboutcookies.org/ website.
If you have any queries about how we treat your information, the contents of this Privacy Notice, your rights under local law, how to update your records or how to obtain a copy of the information that we hold about you, please write to our Operations Director, Peter Meek, at Miles House, Easthampstead Road, Bracknell, Berkshire, RG12 1NJ, UK, call us on +44 1344 861133 or email us at email@example.com.
The General Data Protection Regulation GDPR (GDPR) is European Parliament legislation that'll be introduced in the UK on the 25th May 2018. The GDPR aims to make sure that organisations look after your information and are clear about what they're using it for. It'll also give you more control over how it's used.
Why are we changing our Privacy Notice?
We know the importance of keeping personal data safe and secure. And we appreciate that when you share your data with us, you trust us to look after it. So we've made a few changes to our Privacy Notice and reaffirmed our commitment to protect your rights and interests. (Don't worry, it's all good news.)
The GDPR divides organisations processing personal data into “data controllers” and “data processors.” A data controller determines the purposes and means of the data processing and tells the processor what to do with the data. A data processor processes personal data on behalf of the controller pursuant to the controller’s instructions. Data controllers must comply with the GDPR’s principles, including transparency and lawfulness of the processing. Data processors must act pursuant to the controller’s instructions, secure the data, and help data controllers comply with the GDPR.
Miles 33 is a Data Processor when it acts as a systems or service provider to our customers. Our customers are data controllers for the data they maintain in our systems since they decide what data we process.
As a data processor, we are responsible for complying with our contractual obligations and instructions in our customer agreements, including assisting our customers to comply with their GDPR obligations, securing data, keeping records of how we process personal data on behalf of our customers, preparing to notify our customers in the event of a data breach, and co-operating with EU data protection authorities on request
Miles 33 is a Data Controller for its employees and contractors
For those customers that have Data Processing clauses in their contracts with us, we will clarify, on an individual basis, whether these contracts need to be revised as a result of the new GDPR.