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MS-UK privacy policy

MS-UK privacy policy
Introduction
MS-UK respects your privacy and is committed to protecting your personal data. This privacy
policy will inform you as to how we look after your personal data (in all situations where we collect
your data, or you provide data to us) and tell you about your privacy rights and how the law
protects you.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how MS-UK collects and processes your
personal data through all means such as when you complete a contact us form on our website;
become a client of MS-UK or use our website, including any data you may provide through our
website when you sign up to our newsletter or download a leaflet.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair
processing policy 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 policy supplements the other policies and is not intended to override them.
Controller
MS-UK is the controller and responsible for your personal data (collectively referred to as MS-UK,
“COMPANY”, “we”, “us” or “our” in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal
rights, please contact us.
Contact details
Our full details are:
Telephone: 01206 226500
Email address: info@ms-uk.org
Postal address: MS-UK, Unsworth House, Hythe Quay, Colchester, Essex CO2 8JF

You have the right to make a complaint 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 so
please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
This version was last updated on 23 May 2018.

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
This 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 policy 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 follows:
? Identity Data may include first name, maiden name, last name, username or similar
identifier, marital status, title, date of birth and gender
? Contact Data may include invoicing address, email address and telephone numbers.
? Financial Data may include bank account and payment card details
? Transaction Data may include details about payments to and from you and other details of
services you have received from us
? Technical Data may include 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 this website
? Profile Data may include your purchases or orders made by you, your interests,
preferences, feedback and survey responses
? Usage Data may include information about how you use our services and website
? Marketing and Communications Data includes your preferences in receiving marketing
from us and our third parties and your communication preferences
? Special Categories of Personal Data about you (this includes details about your race or
ethnicity, religious or philosophical beliefs, sex life, sexual orientation, information about
your health and genetic and biometric data), information about criminal convictions and
offences
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 policy.
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 services). In this case,
we may have to cancel a 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 when
engaging our services, filling in forms or by corresponding with us by post, phone, email,
and telephone or otherwise. This includes personal data you provide when you:
o Enquire and or contract with us for our services
o Subscribe to our publications
o Request marketing to be sent to you
o Enter a competition, promotion or survey
o Give us some feedback
? Automated technologies or interactions. 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. Please see our cookie policy at www.ms-uk.org/policies for further details
? Third parties or publicly available sources. We may receive personal data about you
from various third parties
o Technical Data from the following parties:
(a) Analytics providers
(b) Advertising networks
(c) Search information providers
(d) Third party service providers
(e) External fundraising platforms
? Contact, Financial and Transaction Data from providers of technical and payment services
? Identity and Contact Data from data brokers or aggregators
? Identity and Contact Data from publicly available sources
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 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
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.
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 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
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your
order or deliver a service to
you, including:
(a) Manage payments, fees
and charges
(b) Collect and recover money
owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
(f) Special Categories
of Personal Data
(a) Performance of a contract with
you
(b) Necessary for our legitimate
interests (to recover debts due to us)
To manage our relationship
with you which will include:
(a) Notifying you about
changes to our terms or
privacy policy
(b) Asking you to leave a
review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
(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)
To enable you to partake in a
prize draw, competition or
complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Special Categories
of Personal Data
(a) Performance of a contract with
you
(b) 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)
(a) Identity
(b) Contact
(c) Technical
(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
To make suggestions and
recommendations to you
about goods or services that
may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests
(to develop our products/services
and grow our business)
Marketing and
measurement Type of data Lawful basis
Third parties
involved in
processing
To use data
analytics to
improve our
website,
products/services,
marketing,
customer
relationships and
experiences
(a) Technical
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)
Google Analytics
(b) Usage
To send Email
Marketing
messages about
services we offer,
and content that
we create
(a) Identity We rely exclusively on consent
for email marketing activity.
Users can opt themselves into
receiving our marketing on one
of the contact forms on our
website. Users can opt out of
marketing activity by clicking
the unsubscribe link in the
emails they receive, or by
contacting us directly. Records
of consent are maintained in
Mailchimp.
Mailchimp
(b) Contact
(c) Marketing and
Communications
To target display
advertising to
users that have
previously visited
our website and
(a) Technical Necessary for our legitimate
interests (to define customer
types and serve relevant
messaging to users that are
Google Adwords
& Google
Analytics,
Facebook,
(b) Usage
(c) Profile
shown interesting
in our products
and services
interested in our products &
services).
No Identity or contact data is
used in this process. Users
can opt out of processing in
this way by blocking cookies.
Twitter,
Instagram
To analyse user’s
sessions on our
website, by
recording their
mouse
movements and
website
behaviours to
identify website
issues and
improve the users
experience.
(a) Technical Necessary for our legitimate
interests (to keep our website
updated, free from issues, and
provide the best possible user
experience.
We use this data to measure
how users are interacting with
our site, which elements of the
site are causing problems with
the user experience, and if
there are any errors with the
site. This also includes
replaying sessions and
watching interactions back.
No Contact or Identity
information is recorded or
processed. Users can opt out
by blocking cookies.
Google Analytics
(b) Usage
(c) Profile
To track inbound
phone calls, and
the traffic sources
they originated
from
(a) Contact Necessary for our legitimate
interests (to measure the
success of our marketing
activity and update our
marketing and business
development strategies
appropriately).
We use this data to allow us to
measure inbound call volumes
from marketing activity. The
users phone number is
recorded when they call
through but is not processed in
Infinity Call
Tracking
(b) Technical
(c) Usage
(d) Profile
anyway in future unless
permission is granted to do so.
Users can opt out of this by
blocking cookies.
To measure
interactions with,
and how you
share our content
on social
networks
(a) Technical Necessary for our legitimate
interests (to allow users to click
through to, follow and like, or
share our content on social
media).
Data is collected by social
media platforms when users
use their share, like and follow
buttons. For access to this
information, or to opt out, users
can adjust their account
settings on the relevant
platforms.
Facebook,
LinkedIn, Twitter,
Instagram
(b) Usage
(c) Profile
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 services from us or if you provided us with your details when you entered a competition
or registered for a promotion and, in each case, you have not opted out of receiving that
marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company
outside the company for marketing purposes.
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.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set
or access cookies. If you disable or refuse cookies, please note that some parts of this website
may become inaccessible or not function properly. For more information about the cookies we
use, please see our policy at www.ms-uk.org/policies.
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 paragraph 4 above.
? External Third Parties as set out in the Glossary
? Specific third parties listed in the table in paragraph 4 above
? 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 policy
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.
6. International transfers
Many of our external third parties are based outside the European Economic Area (EEA) so their
processing of your personal data will involve a transfer of 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. For further
details, see European Commission: Adequacy of the protection of personal data in non-EU
countries
? Where we use certain service providers, we may use specific contracts approved by the
European Commission which give personal data the same protection it has in Europe. For
further details, see European Commission: Model contracts for the transfer of personal data
to third countries
? Where we use providers based in the US, we may transfer data to them if they are part of
the Privacy Shield which requires them to provide similar protection to personal data
shared between the Europe and the US. For further details, see European Commission:
EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
7. 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.
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 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.

By law we have to keep basic information about our customers (including Contact, Identity,
Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be
associated with you) for research or statistical purposes in which case we may use this
information indefinitely without further policy to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your
personal data. Please click on the links below to find out more about these rights:
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, machinereadable 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.
If you wish to exercise any 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 you 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 a 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 service/product 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 a 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.
Third parties
External third parties
? Service providers acting as processors based within or outside of the EEA who provide
services that support our services supplied to you
? Professional advisers acting including lawyers, bankers, auditors and insurers based within
the EEA who provide consultancy, banking, legal, insurance and accounting services
? HM Revenue & Customs, regulators and other authorities based in the United Kingdom
who require reporting of processing activities in certain circumstances.
Document updated May 2018.