Summary – This Policy |
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This Policy explains how we Process Personal Data. This Policy may be amended or updated from time to time, so please check it regularly for updates. |
This Policy is issued by each of the Controller entities listed in Section (R) below (together, “ MSI ”, “ we ”, “ us ” and “ our ”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, users of our Apps, other users of our products or services, and visitors to our premises (together, “ you ”). Defined terms used in this Policy are explained in Section (S) below.
This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.
Summary – Collection of Personal Data |
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We collect or obtain Personal Data: when those data are provided to us (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make Personal Data public (e.g., if you make a public post about us on social media); when you download, install, or use any of our Apps; when you visit our Sites; when you register to use any of our Sites, Apps, Products, or services; or when you interact with any third party content or advertising on a Site or in an App. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities). |
Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:
Summary – Creation of Personal Data |
We create Personal Data about you (e.g., records of your interactions with us). |
We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us.
Summary – Categories of Personal Data we Process |
We Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; payment details (e.g., your billing address); information about our Sites and Apps (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us. |
We Process the following categories of Personal Data about you:
Summary – Sensitive Personal Data |
We do not seek to collect or otherwise Process Sensitive Personal Data. Where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law. |
We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:
If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.
Summary – Purposes of Processing and legal bases for Processing |
We Process Personal Data for the following purposes: providing our Sites, Apps, Products, and services to you; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our Sites, Apps, Products, and services; fraud prevention; and recruitment and job applications. |
The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:
Processing activity | Legal basis for Processing |
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Summary – Disclosure of Personal Data to third parties |
We disclose Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Sites or our Apps. |
We disclose Personal Data to other entities within the MSI group, for legitimate business purposes and the operation of our Sites, Apps, Products, or services to you), in accordance with applicable law. In addition, we disclose Personal Data to:
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.
Summary – Profiling |
Personal Data are subject to automated decision-making and Profiling. |
We Process Personal Data for the purposes of automated decision-making and Profiling, which is carried out for the following purposes:
Profiling activity | Logic of the Profiling activity | Consequences for you |
Credit scoring | Where we engage a third party (e.g., a credit reference agency) to provide us with information about your credit score and/or credit history. This information is analysed to determine the most appropriate terms on which to offer you credit, where applicable. | This Profiling activity may affect whether you are able to obtain credit, and the interest rates applicable to any such credit. |
Customised discounts | Where we analyse your purchasing activity and your interests. This information is analysed to determine the most appropriate promotions and discounts to offer you. | This Profiling activity may mean that you receive discounts that are not available to others, and that others receive discounts that are not available to you. |