Privacy policy

Introduction

MacBryde Consulting 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 when you visit our website (regardless of where you visit it from).

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how MacBryde Consulting collects and processes your personal data if it collects or porcesses any through signing up to any online service,  filling out a contact form or otherwise.  

This website is not intended for children and we do not intend to 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 if 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. 

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

We may change this policy by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective October 1st, 2019.

It is important that any personal data that we hold about you is accurate and current. Please keep us informed if any personal data given to us changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications or store cookie files on your computer in order to deliver its service(s). Clicking on those links or enabling those connections may allow third parties to collect, store 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).

There are different kinds of personal data a, which we have grouped together as follows: 

• Identity Data includes first name and last name.
• Contact Data includes company name and email address.
• Technical Data includes internet protocol (IP) address, any 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 includes any username or similar identifier and password, any interests, preferences, feedback and survey responses.  
• Usage Data includes any information about how you use our website, products and services. 
• Marketing Data includes any preferences for receiving marketing from us and any communication preferences.
• Communications Data includes any communications we have with you whether by email, post, phone or otherwise.  

We may 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 may not be considered personal data 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.

If you fail to provide personal data

If we need to collect personal data by law, or under the terms of any 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?

If we collect any data about you, we may use different methods including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you 
  • If you apply for any products or services;
  • If you create an account on our website;
  • If you subscribe to any service or publications; 
  • If you request marketing to be sent to you;
  • If you 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. Please see our cookie policy for further details.
• 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, storage, tools and media providers; 
2. IP tracking service providers based within the EU;
3. automated quality control tools based within the EU;
4. automated security and compliance tools based outside the EU;
5. social media and media networks such as Twitter, LinkedIn, Instagram, YouTube and Vimeo based outside the EU; and
6. email distribution and survey providers based outside the EU;
7. identity and Contact data from providers of data feeds and hosting services.

4. How we use your personal data

We will only use any personal data when the law allows us to. Most commonly, any personal data would be used in the following circumstances:

• Where we need to perform a 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.

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 any personal data that we may collect. We have also identified what our legitimate interests are where appropriate.

Note that we may process any personal data for more than one reason depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific reason for processing your personal data.

1. To register you as a new customer

Type of data

(a) Identity
(b) Contact

Legitimate interest

Performance of a contract with you

2. To process and deliver any order

This includes:

(a) Managing payments, fees and charges
(b) Collecting and recovering money owed to us

Type of data

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

Legitimate interest

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)

3. To manage any relationship with you 

This includes:

(a) Notifying you about changes to our terms or privacy policy
(b) Answering any queries you may have

Type of data

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

Legitimate interest

(a) Performance of any 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)
(d) To deal with your enquiries

4. To administer and protect our business and this website 

This includes troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.

Type of data

(a) Identity
(b) Contact
(c) Technical

Legitimate interest

(a) Necessary 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) May be necessary to comply with a legal obligation

5. To deliver relevant website content to you and measure or understand the effectiveness of that content to you

Type of data

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

Legitimate interest

Necessary to study how customers may use our products/services, to develop them, to grow our business and to inform our marketing strategy

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

Type of data

(a) Technical
(b) Usage

Legitimate interest

Necessary 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

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

Type of data

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

Legitimate interest

Necessary to develop our products/services and grow our business

Opting out

You can ask us or third parties to stop sending any marketing messages at any time by contacting us. 
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 or experience or other transactions.

Cookies

Cookies are small text files that are placed on your computer by websites that you visit.  For more information about the cookies we use, please see our cookie policy.

Change of purpose 

We will only use any personal data for the purposes for which we collect 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. 

5. Disclosures of your personal data

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

• Internal Third Parties as set out in the Glossary.
• External Third Parties 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 do not allow any third-party service providers to use your personal data for their own purposes and would only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

If your personal data is transferred, we ensure a similar degree of protection is afforded as described in this privacy policy:

• If data is transferred to the European Economic Area (EEA), we provide an adequate level of protection for personal data as set out by the European Commission.

7. Data security

We have put in place appropriate security measures to prevent any personal data collected from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to any personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on our instructions and they are subject to a duty of confidentiality. 

8. Data retention

How long will you use my personal data for?

We will only retain any 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 any personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of the personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and any applicable legal requirements.

In some circumstances we may anonymise any 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 notice to you.

9. Your legal rights

Under certain circumstances, you may have rights under data protection laws in relation to your personal data: 

• No fee usually required

You will not usually have to pay a fee to access personal data. 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 any personal data . This is a security measure to ensure that any personal data is not disclosed to a 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.

10. Glossary

LEGITIMATE INTEREST

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 any personal data for our legitimate interests. We do not use any personal data for activities where our interests are overridden by any impact on you (unless we have your consent or are otherwise required or permitted to by law). 

Performance of Contract means processing any 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 any personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Any other companies in the MacBryde Consulting Group. 

External Third Parties

• Digital service providers who provide a number of services, including but restricted to data feeds, hosting, SSL, data analysis, CRM, video streaming, social media and sharing services.
• Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance accounting or other professional services.
• Regulators and other authorities who require reporting of activities in certain circumstances.
• Marketing services providers including mailing and survey companies who provide distribution, reporting and analysis of emails and surveys.