MOT Models Limited – Privacy Policy
Website Privacy Policy
Welcome to the MOT
Models Limited privacy notice
MOT Models Limited 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) and tell you about
your privacy rights and how the law protects you.
This privacy notice is
provided in a layered format so you can get 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 MOT Models Limited collects and processes your
personal data through your use of this website, including any data you may
provide through this website when you sign up to our newsletter, purchase a
product or service or take part in a competition.
This website is not
intended for children and we do not knowingly collect data relating to children
through this web-site.
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 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 notice supplements the other notices
and is not intended to override them.
CONTROLLER
MOT Models Limited is
the controller and responsible for your personal data.
This privacy notice is
issued on behalf of the MOT Models Limited so when we mention MOT Models, MOT
Models Limited, “we”, “us” or “our” in this privacy notice, we are referring to
the relevant company responsible for processing your data. MOT Models Limited
is the controller and responsible for this website.
We have appointed a data
protection officer (DPO) who is responsible for overseeing questions in
relation to this privacy notice. If you have any questions about this privacy
notice, including any requests to exercise your legal rights, please contact
the DPO using the details set out below.
CONTACT DETAILS
Our full details are:
Full name of legal
entity: MOT Models Limited
Name or title of DPO:
GDPR
Email address:
gdpr@motmodel.com
Postal address: The
Stables, Ashlyns Hall, Chesham Road, Berkhamsted, Herts HP4 2ST, United Kingdom
Telephone number: +44
(0)1442 863918
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
NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last
updated on 24/5/2018.
The data protection law
in the UK will change on 25 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 does include
links to a third-party website and applications which process payments by
credit card. 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).
We may collect, use,
store and transfer different kinds of personal data about you which we have
grouped together follows:
•
Identity Data includes first name, last name, username or
similar identifier, date of birth.
•
Contact Data includes billing address, delivery address,
email address and telephone numbers.
•
Financial Data includes bank account and payment card details.
•
Transaction Data includes details about payments to and from you
and other details of products and services you have purchased from us.
•
Technical Data includes 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 includes your username and password,
purchases or orders made by you.
•
Personal Statistics for proposing you as a model / actor
•
Marketing and Communications Data includes your
preferences in receiving marketing from us.
•
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 notice.
We do not collect any Special
Categories of Personal Data about you (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) through this web-site. Nor do we collect
any information about criminal convictions and offences.
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 goods or
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 by filling in forms or by corresponding with us by post,
phone, email or otherwise. This includes personal data you provide when you:
• apply for our
products or services;
• create an
account on our website;
• subscribe to
our service or publications;
• request
marketing to be sent to you;
• enter a
competition, promotion or survey; or
• 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 server logs and other similar technologies.
•
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 analytics providers such as Google based outside the EU;
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 third party 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 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
|
(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
|
(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 deliver
relevant website content and advertisements to you and measure or understand
the effectiveness of the advertising we serve to you
|
(a)
Identity
(b) Contact
(c) Profile
(d) Usage
(e)
Marketing and Communications
(f)
Technical
|
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
|
(a)
Technical
(b) Usage
|
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 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
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 through us 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 do not normally do any third-party marketing
but in the event that we do, we will get your express opt-in consent before we
share your personal data with any company outside MOT Models Limited for
marketing purposes.
OPTING OUT
You can ask us or third
parties to stop sending you marketing messages at any time by email us at gdpr@motmodel.com with explicit
instructions.
Where you opt out of
receiving these marketing messages, this will not apply to personal data
provided to us as a result of a service purchase or other business transaction.
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. AT time of
writing we only use cookies for model and client portfolio downloads.
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 email us at gdpr@motmodel.com.
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.
•
Internal Third Parties as set out later in this document.
•
External Third Parties as set out later in this document.
•
Specific third parties.
•
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 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
We share your personal
data within MOT Models Limited. However, this may involve transferring your
data outside the European Economic Area in order to conduct normal business
with you or through you. We will ensure your personal data is protected by
requiring all our group companies to follow the same rules when processing your
personal data.
At time of writing, our
external third parties may be 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 email us at gdpr@motmodel.com
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.
OR
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).
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 notice to you.
9. YOUR
LEGAL RIGHTS
Under certain
circumstances, you have rights under data protection laws in relation to your
personal data.
•
You may request access to your personal data
•
You may request that your personal data be corrected
•
You may request erasure of your personal data
•
You may object to the processing of your personal data
•
You may Request restriction of processing your personal data
•
You may Request transfer of your personal data
•
You may withdraw consent for us to hold your personal data
If you wish to exercise any of the rights set out above, please contact
our DPO or email gdpr@motmodel.com
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 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 at gdpr@motmodel.com .
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
INTERNAL THIRD PARTIES
Other companies in MOT
Models Limited and providing IT and system administration services and
undertake leadership reporting.
EXTERNAL THIRD PARTIES
•
Service providers (acting as processors) based in the EEA or USA
who provide IT and system administration services.
•
Professional advisers including lawyers, bankers, auditors and
insurers (acting as processors) based in the EEA and USA who provide consultancy,
banking, legal, insurance and accounting services.
•
HM Revenue & Customs, regulators and other authorities (acting
as processors) based [in the United Kingdom] [who require reporting of
processing activities in certain circumstances].
YOUR LEGAL RIGHTS
You have the right to:
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, machine-readable 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.