MINTON, TREHARNE & DAVIES LTD (MTD) PRIVACY NOTICE.
Under the General Data Protection Regulation (GDPR) ‘Personal Data’ is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
MTD respects your privacy and is committed to protecting your Personal Data. This Privacy Notice will inform you as to how we look after your Personal Data, tell you about your privacy rights and how the law protects you.
1.0 Purpose of this Privacy Notice
1.1 This Privacy Notice aims to give you information on how MTD collects and processes your Personal Data.
1.2 It is important that you read this Privacy Notice so that you are fully aware of how and why we are using your data.
2.0 Contact details
2.1 Our full details are:
Full name of legal entity: Minton Treharne & Davies Ltd
Postal address: Longwood Drive, Forest Farm Industrial Estate, Cardiff, Wales, CF14 7HY.
Telephone number: +44 (0) 29 2054 0000
3.0 Changes to the Privacy Notice and your duty to inform us of changes
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.
4.0 The data we collect about you
4.1 We collect, use, store and transfer different categories of Personal Data about you which we have grouped together as follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account, payment card details, and payroll data.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or intranet.
• Profile Data includes your username and password on our website, our intranet, purchases or orders made by you, your preferences, and feedback and survey responses.
• Usage Data includes information about how you use our website, intranet, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
4.2 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly 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 Privacy Notice.
4.3 Special Categories of Personal Data these are 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). We do not normally collect any special categories of data nor do we collect any information about criminal convictions and offences other than as set in clause 4.4. below or for our employees or applicants for employment. If we do need to processes such data we will ask for your explicit consent to do so, except in relation to where you order Covid 19 tests from us as further detailed in clause 4.4 below.
4.4 Covid-19 Testing. Where you have requested a Covid-19 testing service, you will be required to undertake a swab test. This service will require you to provide us with Personal Data, including, but not limited to genetic data, in order for your swab to be processed by a laboratory so that you may receive the results of your test, which we will also have access to. We have set out in the table under clause 8, a description of the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so.
5.0 If you fail to provide Personal Data
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 or employee benefits). 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.
6.0 We use different methods to collect data from and about you including through:
6.1 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, and e-mail or otherwise. This includes Personal Data you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a promotion or survey;
• give us some feedback;
• provide unsolicited information to us;
• apply for employment with us or when you become an employee.
6.2 Automated interactions. As you interact with our website or intranet, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, and other similar technologies.
6.3 Third parties (or publicly available sources). We may receive categories of Personal Data about you from various third parties and public sources as set out below:
• Technical Data from analytics providers such as Google; advertising networks and search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from data brokers, aggregators or recruitment agencies.
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register.
7.0 How we use your Personal Data
7.1 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 or regulatory obligation.
7.2 We may also use your Personal Data in the following situations, which are likely to be rare:
• Where we need to protect your interests (or someone else’s interests).
• Where it is needed in the public interest or for official purposes.
7.3 Generally we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending 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.
8.0 Purposes for which we will use your Personal Data
8.1 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.
8.2 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 additional details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.