Privacy Policy
(A) This Policy
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.
(B) Collection of Personal Data
Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:
- Data provided to us:We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).
- Relationship data:We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your employer).
- Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
- App data:We collect or obtain Personal Data when you download or use any of our Apps.
- Site data:We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
- Registration details:We collect or obtain Personal Data when you use, or register to use, any of our Sites, Apps, Products, or services.
- Content and advertising data:If you interact with any third party content or advertising on a Site or in an App (including third party plugins, cookies, tags, or other data that may identify you or enable us to track advertising conversions) we receive Personal Data from the relevant third party provider of that content or advertising. We also process records of your interactions with our online advertising and content, records of advertising and content displayed on a Site in an App, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
- Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).
(C) Creation of Personal Data
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.
(D) Categories of Personal Data we Process
We Process the following categories of Personal Data about you:
- Personal details:given name(s); preferred name; and photograph.
- Demographic information:gender; date of birth / age; nationality; salutation; title; and language preferences.
- Contact details: correspondence address; shipping address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
- Consent records:records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
- Purchase details:records of purchases and prices; consignee name, address, contact telephone number and email address.
- Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or account holder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheque.
- Data relating to our Sites and Apps:device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; location data, and other technical communications information (some of which may constitute Personal Data); username; password; security login details; usage data; aggregate statistical information.
- Employer details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.
- Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
- Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
(E) Sensitive Personal Data
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:
- Compliance with applicable law:We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
- Detection and prevention of crime:We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
- Establishment, exercise or defense of legal rights:We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defense of legal rights; or
- Consent:We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
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.
(F) Purposes of Processing and legal bases for Processing
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:
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(G) Disclosure of Personal Data to third parties
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:
- you and, where appropriate, your appointed representatives;
- legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- accountants, auditors, lawyers and other outside professional advisors to MSI, subject to binding contractual obligations of confidentiality;
- third party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);
- any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
- any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
- any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
- any relevant third party provider, where our Sites and our Apps use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.
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.
(H) 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 |
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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. |
Customized 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. |