Branded Privacy Policy

This Privacy Policy provides details of the personal data we collect from you, what we do with it, how you might access it and who it might be shared with.

We will ensure that your personal information is treated with the utmost respect and in accordance with EU General Data Protection Regulation (GDPR) on the protection of individuals with regard to processing of personal data and on the free movement of such data.

Group companies

Branded means Magnet Harlequin Ltd or any of its subsidiaries including:

Magnet Harlequin Limited
Registered at Companies House, Cardiff.
Registration No 1708356.
Registered Address: Unit F, Tomo Estate, Packet Boat Lane, Cowley, Uxbridge, Middlesex, UB8 2JP.

Technik Limited
Registered at Companies House, Cardiff.
Registration No 01278908.
Registered Address: Unit F, Tomo Estate, Packet Boat Lane, Cowley, Uxbridge, Middlesex, UB8 2JP.

Magnet Harlequin Asia Ltd
Registered in Hong Kong.
Registration No 1590376.
Registered Address: Units C & D, 11/F, Block 1, Camelpaint Building, 62 Hoi Yuen Road, Kwun Tong, Kowloon, Hong Kong.

Security and performance

We maintain the security and performance of our data handling systems and website through controls which are part of our Information Security Management System (ISMS

We have carried out assessments of the legal basis for processing personal data and have concluded that this is necessary on the grounds of contractual and legal obligations together with our legitimate interests for the use of business and employee data.

How we use your information

This Privacy Policy tells you what to expect when we collect and process personal information.

For professional personal data (e.g. business related data) the legal basis for this is our legitimate interests, namely the control and maintenance of our website and/or business administration and/or the performance or creation of a contract between you and us.

For employment related personal data, the legal basis for this is our legitimate interests, namely the protection and assertion of legal rights and/or the performance or creation of a contract between you and us as an employer and/or employment and fiscal legal obligations.

Should we decide to process any personal data for a purpose other than that for which it was collected, we will provide you with information on that other purpose and with any relevant further information prior to that further processing.

Visitors to our websites

When someone visits our website we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website.

In order to provide you with our products and services, or to reply to any enquiries, we collect professional information (e.g. business related data) about you and your company submitted to our websites, passed on during telephone conversations, included in emails and mobile messaging and any other form of written or verbal communication. For example, we might keep a record of your name, work address and associated delivery addresses, work email address and work telephone number/s.

We have detailed below the 3rd parties we share your data with.

Where we want to collect personal data we will make this clear and will explain what we intend to do with it.

By continued use of our website, you consent to the Company collecting analytical and professional information about you and your organisation in accordance with the terms set out in this Policy. You also consent to the Company using the analytical and professional information for market research, marketing, sales, customer relationship management (CRM), operational, financial and legal purposes in accordance with the terms set out in this Policy.

Services
We offer various services to businesses and professionals. We have to hold the details of the people who have requested our services in order to provide them. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have requested a service to carry out a survey to find out if they are happy with the level of service they received. When people do subscribe to our services, they can cancel their subscription at any time and are given an easy way of doing this.

Cookies
The Internet browser that you use may make use of a feature called a ‘cookie’ to assign identification to your computer. On our websites, we do not use cookies to store personal data or to link personal data to non-personal data, unless you have first agreed to this by selecting the ‘Remember Me’ option (where applicable), in which case a cookie will be placed on your computer which will allow the site to recognise you when you return. No personal information will be stored in this cookie.

Google Analytics
We use Google Analytics to help provide anonymous web analytics for this site.

These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. 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.

Email marketing
From time to time we use a third-party vendor, Campaign Monitor, to deliver e-newsletters. We deliver these only to email addresses where we believe we have a legitimate interest in the personal data. Each email contains clear instructions to opt out of further mailings. We regularly clear our lists of inactive and irrelevant data.

We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter and to improve our understanding of whether our emails are valued by you. https://www.campaignmonitor.com/policies/#privacy-policy

Social media
We use a third party provider, Hootsuite, to manage our social media interactions.

If you send us a private or direct message via social media the message will be stored by Hootsuite for three months. It will not be shared with any other organisations.

Email
Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.

Applicants, current and former employees
We are the data controller for the information you provide during job application processes, current employment and management of past employment records, unless otherwise stated.

Our primary means of handling recruitment processes is our email system and telephone contact. Some records may be stored on restricted access areas of the company’s own servers and any paper records will be retained in a locked area of the office accessible only to the HR team.

If you have any queries about the process, the questions we will ask during a recruitment process for any given role, the personal data we will manage during employment or after it, please contact us at privacy@magharl.co.uk

Retention
We only retain personal data for as long as necessary to satisfy the following requirements:

Legal
We are required to meet our legal obligations regarding the retention periods for some data, such as financial records and information (7 years for data relating to financial transactions).

Contractual
Your data will be retained for the duration of your contract term, to enable us to fulfil our contractual obligations. We may retain this data for a further period of 18 months for marketing and business analysis purposes.

Marketing
Where we hold data for marketing purposes, then it is retained for a period of 18 months of inactivity.

Recruitment
Recruitment and employment records are typically kept only for as long as necessary to fulfil our legal obligations, but no longer than six years after last contact.

Your rights
Under the Data Protection Act and EU GDPR, you have rights as an individual which you can exercise in relation to the information we hold about you, namely;

  • The right to be informed: why we process the personal data, who we share the data with and how long we will store the data for (see above)
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • The right not to be subject to an automated decision


You can read more about these rights at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/

How can you access your personal data?
We try to be as open as we can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘Subject Access Request’. If we do hold information about you we will:

  • give you confirmation as to whether or not we are holding any personal data about you and if yes, a description of it
  • tell you why we are holding it and how long for
  • tell you your rights in respect of personal data held by us
  • tell you who it could be disclosed to
  • let you have a copy of the information in an intelligible form.


However the right to obtain a copy must not adversely affect the rights and freedoms of others.

To make an enquiry about any personal information we may hold, you need to put the request in writing addressing it to our Data Protection Officer, at the address provided below.

If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.If we do hold information about you, you can ask us to correct any mistakes or exercise any of your other rights by, once again, contacting the Data Protection Officer.

Disclosure of personal information
Generally we will not disclose personal data to third parties not listed in this Policy without your consent. However there may be circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymised statistics.

Complaints or queries
We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This Privacy Policy was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.

If you want to make a complaint about the way we have processed your personal information, you can contact the ICO (the statutory body which oversees data protection law) at https://ico.org.uk/global/contact-us/

Links to other websites
This Privacy Policy does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

Changes to this Privacy Policy
We keep our Privacy Policy under regular review. Please ensure you look at it regularly to be aware of any updates.

How to contact us
You can write to:
The Data Protection Officer
Branded
Tomo Estate
Packet Boat Lane
Cowley
Uxbridge
UB8 2JP
United Kingdom