Privacy Policy

1. Introduction

https://www.mppglobal.com/  (Website) is provided by MPP Global Solutions Ltd (we, our or us). We are the controller of personal data obtained via our Website, meaning the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your Personal Data) in connection with your use of our Website. It also explains your rights in relation to your Personal Data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain Personal Data about you. When we do so we are subject to the GDPR as it applies in the UK and as it applies in relation to services we offer to individuals and our wider operations in the European Economic Area (EEA).

Given the nature of our Website, we do not expect to collect Personal Data of children and this Privacy Notice is therefore written for adults.

2. What this Privacy Notice applies to

This Privacy Policy relates to the use of our Website only. 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 gather information 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.

3. Personal Data we collect about you

The Personal Data we collect about you depends on the particular activities carried out through our Website. We may collect and use the following Personal Data:

Identity and Contact Data includes first name, last name, email address and telephone numbers.

Technical Data includes internet protocol (IP) address, 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.

Usage Data includes information about how you use our Website.

Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We do not collect any Special Category Personal Data (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 and offences.

We may collect and use this Personal Data for the purposes described ‘How and why we use your Personal Data’ below.

4. How is your Personal Data collected?

We collect Personal Data from and about you:

• directly when you enter or send us information, such as when you:
• contact us (including via email)
• subscribe to our newsletters or publications;
• attend on one of our webinars;
• apply for our whitepapers or guidance documents;
• request marketing to be sent to you;
• complete customer surveys or participate in competitions via our Website; or
• send us feedback.
• indirectly when you interact with our Website; we may automatically collect information indirectly using cookies and other similar tracking technologies about your equipment, browsing actions and patterns.

5. How and why we use your Personal Data

1. Under data protection law, we can only use your Personal Data if we have a lawful basis to do so e.g.:
   • where you have given consent;
   • to comply with our legal and regulatory obligations;
   • for the performance of a contract with you or to take steps at your request before entering into a contract; or
   • for our legitimate interests or those of a third party.

   A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

   The table below explains what we use your personal data for and why.

   What we use your Personal Data for	Type of data	Our reasons
   To manage our relationship with you which will include: (a) Providing you with access to Whitepapers, Free Downloads, Webinars Notifying you about changes to our terms or changes to this Privacy Notice (b) Asking you to leave a review or take a survey	Identity and Contact data Marketing and Communications data	(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 you access and use our products/services)
   To enable you to partake customer surveys or competitions via our Website	Identity and Contact data Marketing and Communications data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how you use our products/services, to develop them and grow our business)
   To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity and Contact data Technical data	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)
   To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity and Contact data Marketing and Communications data Technical data Usage data	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	Technical data Usage data	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 products/services that may be of interest to you	Identity and Contact data Marketing and Communications data Technical data Usage data	Necessary for our legitimate interests (to develop our products/services and grow our business)

    

6. Marketing and Opting Out

1. We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We may use your Personal Data to send you updates (by email, text message, telephone or post) about our products or services. We have a legitimate interest in using your Personal Data for marketing purposes (see above ‘How and why we use your Personal Data’), This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.You have the right to opt out of receiving marketing communications at any time by:
   • contacting us (see below ‘How to contact us’)
   • using the ‘unsubscribe’ or opt-out link on any marketing message sent to you.

   We may ask you to confirm or update marketing preferences if you ask us to provide further products or services in the future, or if there are changes in the law, regulation or the structure of our business.

   We will always treat your Personal Data with the utmost respect and never sell or share it with other organisations outside the MPP Global group for marketing purposes. For more information on your right to object at any time to your Personal Data being used for marketing purposes. See ‘Your Rights’ below.

7. Do we share your Personal Data?

1. We share your Personal Data with third parties we use to help us run our business e.g., marketing atomisation providers, website hosts and website analytics providers.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.

8. How long your Personal Data will be kept

1. 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.Details of retention periods for different aspects of your Personal Data are available in our Data Retention Policy which you can request from us by contacting us (see below ‘How to contact us’)

9. International Transfers

1. Depending on how you use our site your Personal Data will usually only be stored in the UK.We may share your Personal Data to countries outside the UK to other entities within the MPP Global group. In those cases, we will comply with applicable UK laws designed to ensure the privacy of your Personal Data.Under data protection laws, we can only transfer your Personal Data to a country outside the UK or EEA or to an international organisation where:
   • the particular country ensures an adequate level of protection of Personal Data (known as an ‘adequacy regulation’). A list of countries the UK currently has adequacy regulations in relation to is available Here and includes the EEA. A list of countries the European Commission has currently made adequacy decisions in relation to is available Here and includes the UK.
   • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
   • a specific exception applies under relevant data protection law.

   Where we transfer your Personal Data outside the UK or EEA we do so on the basis of an adequacy regulation or using standard data protection clauses recognised or issued further to Article 46(2) of the GDPR as it applies in the UK or EEA. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your Personal Data outside the UK unless we can do so based on an alternative mechanism or exception provided by UK data protection law.

   Any changes to the destinations to which we send Personal Data or in the transfer mechanisms we use to transfer Personal Data internationally will be notified to you in accordance with the section on ‘Change to this privacy policy’ below.

10. Cookies

1. A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our Website. We use cookies on our Website. Cookies help us recognise you and your device and store some information about your preferences or past actions.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 our Website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.mppglobal.com/cookie-policy/

11. Your Rights

1. You generally have the following rights, which you can usually exercise free of charge:
   

   Access to a copy of your Personal Data	The right to be provided with a copy of your Personal Data.
   Correction (also known as rectification)	The right to require us to correct any mistakes in your Personal Data.
   Erasure (also known as the right to be forgotten)	The right to require us to delete your Personal Data—in certain situations.
   Restriction of use	The right to require us to restrict use of your Personal Data in certain circumstances, e.g. if you contest the accuracy of the data.
   Data portability	The right to receive the Personal Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
   To object to use	The right to object: —at any time to your Personal Data being used for direct marketing (including profiling) —in certain other situations to our continued use of your Personal Data, e.g. where we use your Personal Data for our legitimate interests.
   Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our Website.

   A more detailed explanation of these rights under UK law is available https://ico.org.uk/your-data-matters/

12. Keeping your Personal Data secure

1. We have put in place appropriate security measures to prevent Personal Data from being accidentally lost, used or accessed unlawfully. In addition, we limit access to Personal Data to those who have a genuine business need to access it. 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 security breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.

13. How to complain

1. Please contact us (see below ‘How to contact us’) if you have any queries or concerns about the use of your information. You also have the right to make a complaint with:
   • The Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/make-a-complaint).
   • a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA. For a list of EEA data protection supervisory authorities and their contact details see https://edpb.europa.eu/about-edpb/about-edpb/members_en

   We would, however, appreciate the chance to deal with your concerns before you approach the ICO or other supervisory authority so please contact us in the first instance.

14. Privacy Notice Changes

1. We may change this Privacy Notice from time to time. Any changes will be immediately posted on our Website. We recommend that you check this page regularly to keep up to date.

15. How to contact us

Individuals in the UK

You may contact us by post, email or telephone if you have any questions regarding this Privacy Notice or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are as follows:

MPP Solutions Ltd

Postal address: 401 Faraday Street, Birchwood Park, Warrington, UK, WA3 6GA

Telephone number:  44 844 873 1418

Email address: dataprotection-office@aptitudesoftware.com