Welcome to Microtrading Limited’s privacy notice.

Microtrading Limited 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 and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Microtrading Limited collects and processes your personal data, including any data you may provide through our website when you sign up to our newsletter or purchase a product or service.

Our services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice 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 fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Microtrading Limited is the controller and responsible for your personal data (collectively referred to as “the Company”, “we”, “us” or “our” in this privacy notice). Microtrading Limited is an IT support and services company specialising in helping businesses implement, use and support IT systems.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Full name of legal entity: Microtrading Limited

Name and title of data privacy manager: Andrew Penlington, Director

Email address: ap@microtrading.co.uk

Postal address: Microtrading Limited, System House, 158 Church Road, Birmingham, B25 8UT

Telephone number: 0121 784 0077

We are registered as a Data Controller with the UK Information Commissioner’s Office under registration number ZA361158. You have the right to make a compliant 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 chance to deal with your concerns before you approach the ICO please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was updated on 28th day of June 2018.

The data protection law in the UK changed on 25th May 2018. This privacy notice sets out most of your rights under the new laws.

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.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

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

We may collect, use, store and transfer different kinds 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 and payment details.
  • 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.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect information about your computer and about your visits to and use of this website. This includes collecting unique online identifiers such as IP addresses, which are numbers that uniquely identify a specific computer or other device on the internet. Please see our Cookies section for more details.

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.

We do not collect any Special Categories of Personal Data about you (this 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 or offences.

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). 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.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email 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 competition, promotion or survey; or
    • give us some feedback.
  • Automated technologies and cookies. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

    Cookies are small text files which are stored on your computer when you visit certain web pages. At Microtrading Limited we use cookies to understand how our sites are used which helps us to improve your overall online experience. Some of the cookies we use are necessary for our sites to work. To find out more about cookies visit www.aboutcookies.org. Cookies do not typically contain any information that identifies a user, but other information that we hold about you may be linked to the information stored in, and obtained from, cookies. The types of cookies we use can be attributed to the following categories:

    • Strictly necessary. These cookies are essential for certain features of our website to work. These cookies do not record identifiable personal information and we do not need your consent to place these cookies on your device. Without these cookies some services you have asked for cannot be provided.
    • Performance. These cookies are used to collect anonymous information about how you use our websites. We use Google Analytics to help us understand our website and how the website is used. We use this information to help us improve our websites and the content we provide. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. You can read their privacy policy at www.google.com/policies/privacy/ .
    • Functionality. These cookies are used to provide services or remember settings to enhance your visit, for example text size or other preferences. The information these cookies collect is anonymous and does not enable us to track your browsing activity on other websites.
    • Targeting. These cookies record your visit to our website, the pages you have visited and the links you have followed. We use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
    • Session cookies and persistent cookies. Session cookies expire when you close your browser or if you stay inactive for a period of time. Persistent cookies will persist even after the browser is closed. They are used to remember you so that you don’t have to re-enter information every time you revisit our website. For example, login details.

By continuing to use this site, you are accepting our use of targeting cookies that make advertising more relevant to you and your interests, and further help us to improve the site. If you’d prefer to restrict, block or delete cookies placed by our website, you can use your browser to do this. Each browser is different, so please check the ‘Help’ menu of your particular browser to learn how to change your cookie preferences. Note that if you choose to disable all cookies some features of our website may not be available or work as expected.

The following table provides information on the cookies we use and why:

Service

Cookie name

Purpose

Google Analytics

_utma

_utmb

_utmc

-utmz

Google Analytics cookies do not collect personal data about our website visitors.

Google Analytics is used to collect information about how visitors use our website. We use this information to understand how our website is used, and therefore how to improve the website. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

Mindmatrix

cmap.amp.vg

Mindmatrix cookies provides further analytical information about the visitors and usage of our website. The Mindmatrix cookies we are using do not store personal data about our website visitors.

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

    • Technical Data from the following parties:
      1. analytics providers such as Google, Mindmatrix based outside the EU;
      2. advertising networks such as LinkedIn, Google Adwords based outside the EU and Facebook based inside the EU: and
      3. search information providers such as Google, Bing based outside the EU.
    • Identity and Contact Data from data brokers or aggregators such as Experian and CreditSafe based inside the EU.
    • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4. How we use your personal data?

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

  • 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.

To find out more about the types of lawful basis that we will rely on to process your personal data please visit the ICO (Information Commissioner’s Office) website https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/ .

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via post, email or text message. You have the right to withdraw consent at any time by contacting us.

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 basis 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 grounding 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 in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

  1. Identity
  2. Contact

Performance of a contract with you

To process and deliver your order including:

  1. Manage payments, fees and charges
  2. Collect and recover money owed to us
  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

  1. Notifying you about changes to our terms or privacy policy.
  2. Asking you to leave a review or take a survey.
  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

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

  1. Identity
  2. Contact
  3. Technical
  1. 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)
  2. Necessary to comply with a legal obligation

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

  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical

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)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

  1. Technical
  2. Usage

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)

To make suggestions and recommendations to you about goods or services that may be of interest to you

  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile
  6. Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

To ensure the company offices and its stored information is secure we use CCTV services

  1. Identity

Necessary for our legitimate interests (to protect company property and meet insurance obligations)

Marketing

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

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data 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 products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us or third parties 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 provided to us as a result of a product/service purchase, warranty registration, product/service experience 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 get 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, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in point 4 above.

  • The workers who deliver our services
  • External third parties who provide a service to us as set out in the Glossary
  • Third parties to whom we may choose to sell, transfer, or merge 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 notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We shall keep your personal data within Microtrading Limited and our trusted third parties except where disclosure is required by law, for example to government bodies and law enforcement agencies. 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.

6. International transfers

Your personal data may be stored, processed and transferred outside of the United Kingdom and European Economic Area so that we can use your personal data as described in this privacy notice. These countries include:

  • United States of America

We will make sure that any transfer of your personal information from one country to another comply with those data protection and privacy laws which apply to us. European data protection laws include specific rules on transferring information outside the European Economic Area.

When transferring personal information outside the European Economic Area, we will:

  • Include standard data protection clauses approved by the European Commission for transferring personal information outside the European Economic Area into our contracts with those third parties (these are the clauses approved under Article 46.2 of the General Data Protection Regulation); or
  • Ensure that the country in which your personal information will be handled has been deemed “adequate” by the European Commission under Article 45 of the General Data Protection Regulation.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidently lost, used or accessed in an authorised 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.

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

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for, 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.

Where your information is no longer required or is no longer relevant, we will ensure it is disposed of securely.

Details of retention periods for different aspects of your personal data are shown below:

  • Personal details for marketing information will be held for a period of 24 months since your last interaction with us.
  • To make sure that you do not receive marketing from us after you have told us to stop sending it, we need to keep a record of that instruction with our contact details. We shall hold that information until you tell us otherwise.
  • Where necessary, we shall keep your personal data for as long as required to so by law; and where required to establish, exercise or defend our legal rights.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include your ability to:

  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer of your personal data
  • Right to withdraw consent

If you wish to exercise and of the rights set out above, please contact us.

No fee usually required

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.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than one month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best possible product/service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

External Third Parties

  • Service Providers acting as processors including marketing and IT system administration services based in the United Kingdom and United States of America who provide consultancy, hosting and administration services.
  • Professional Advisers acting as processors or joint controllers including lawyers, bankers, auditors, HR advisors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance, HR and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Microsoft acting as processors based in the United Kingdom, European Economic Area and United States of America. For further information visit www.microsoft.com/en-us/trustcenter/
  • Carousel Marketing acting as processors based in the United Kingdom. For further information visit www.carouselmarketing.com
  • Datto acting as processors based in the United Kingdom. For further information visit www.datto.com
  • SolarWinds acting as processors based in the United Kingdom, European Economic Area and United States of America. For further information visit www.solarwinds.com
  • Mindmatrix acting as processors based in United States of America. For further information visit www.mindmatrix.net
  • Connectwise acting as processors based in the United Kingdom and United States of America. For further information visit www.connectwise.com

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those 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.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (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.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.