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PRIVACY POLICY

We are delighted that you have shown interest in our Business. Data protection
is of a particularly high priority for MTD Ebusiness Ltd {Us, We, Our}.  We are
both a controller and a processor under the definitions of General Data
Protection Regulation (GDPR) and for the purposes of Data Protection Act 1998 we
are registered with the UK Information Commissioner’s Office (ICO) as a data
controller under registration number ZA136790.

This privacy notice explains how we process your personal information when you
visit our website – https://www.mtdcnc.com, as a recipient of our marketing, if
you choose to be a customer of ours, or if we have collected, stored or shared
your personal data as part of the legitimate interests of our business.  It
explains how we will protect data subjects {You, your} information and personal
data, and the controls and safeguards we provide for this data. This includes
understanding, at all times, precisely what data we are storing for and about
you, who (if anyone) can see that data, and whether you give permission for that
data to be shared with third-parties.

The processing of personal data, such as the name, address, e-mail address, or
telephone number shall always be in line with the General Data Protection
Regulation (GDPR), The Data Protection Act 2018 and Privacy and Electronic
Communications Regulations (PECR).

By means of this data protection declaration, we would like to inform you of the
nature, scope, and purpose of the personal data we collect, use and process.
Furthermore, data subjects are informed, by means of this data protection
declaration, of the rights to which they are entitled.

Specific data protection declarations will be provided separately for our video
media services, this will allow for the nuances of such event data processing to
be communicated to you in a transparent manner.

As a controller and processor, we are implementing appropriate ‘GDPR Ready’
technical and organisational measures which are documented and managed by our
Information Security Management System (ISMS) and Personal Information
Management system (PIMS), there frameworks, acting in tandem, will ensure the
most complete protection of personal data processed throughout this website, on
our electronic networks and throughout the entirety of our physical estate.

Topics

 1. Who we are?
 2. The information we collect about you, why we need it and who it’s shared
    with?
 3. Our Legal Basis for processing data and Email Marketing
 4. Our website uses cookies, here’s what they do and how you can stop them if
    you wish
 5. Access to your personal data and rights to correct, restrict or delete that
    data
 6. Other websites
 7. Changes to our privacy policy
 8. How long we keep your data
 9. How to contact us or make a complaint


WHO WE ARE?

We work on behalf of manufacturing equipment suppliers and engineers providing
bespoke marketing solutions, for example crafting websites, creating marketing
campaigns and nurturing opportunities. In order to do this, we initiate a blend
of targeted conventional marketing activities such as email marketing,
telemarketing and direct mail. We also provide video media services and work
extensively in the social media market.

We hold a database of sector specific B2B contacts that we have nurtured and
managed so as to provide assurance of provenance. These are professionally
relevant individuals for business marketing emails, business telemarketing and
business direct mail. The scope of our work does not include the consumer
sector.

The information we collect about you, why we need it and who it’s shared with

The personal data we may collect from you and process is:

Personal data type: Source First Name & Last Name Email Subscribe list, Publicly
Available Information, Events, Business Cards, Customers, Website Registrants,
Surveys Job Title Email Subscribe list, Publicly Available Information, Events,
Business Cards, Customers, Website Registrants, Surveys Organisation Email
Subscribe list, Publicly Available Information, Events, Business Cards,
Customers, Website/Email Tracking Tools, Website Registrants, Surveys, Work
Address Email Subscribe list, Publicly Available Information, Events, Business
Cards, Customers, Website/Email Tracking Tools, Website Registrants, Surveys
Email Address Email Subscribe list, Publicly Available Information, Events,
Business Cards, Customers, Website/Email Tracking Tools, Website Registrants,
Surveys Telephone Number Email Subscribe list, Publicly Available Information,
Events, Business Cards, Customers, Website/Email Tracking Tools, Website
Registrants, Surveys Sensitive Data Type: Source None



 

N/A

You do not have to directly provide us with any personal data in order to browse
our website. However, you may provide us with personal data by completing forms
on this website, or by contacting us via telephone or email.

When you visit this website, we will automatically collect the internet protocol
(IP) address of the device used by you, your physical location, as well as the
type of the device, browser version and time zone setting. This will enable us
to identify you as a unique user for analytical purposes, discover your browsing
habits/interests via the pages/links you visit and resources you access;
therefore, allowing us to optimise our website for you, and your device.

This data may be collected and used to ascertain the organisation you work for
and whether you are a professionally relevant post-holder for future marketing
that we, or our affiliates/customers may wish to send to you.

If you contact us by e-mail, subscribe to a mailing list, or via a contact form,
the personal data transmitted by the data subject is automatically stored. Such
personal and non-personal data, transmitted on a voluntary basis by a data
subject to the data controller are stored for the purpose of contacting the data
subject.

We hold personal information relating to existing, previous and prospective
customers and our employees and suppliers.

Our legal basis for processing personal data and Email Marketing

The legal basis we use under the General Data Protection Regulation for the
processing of personal data are:

 * Our legitimate interests
 * Fulfilling out Contractual Obligations
 * Consent
 * Any Legal Requirements we may have such as fraud prevention

Data Processing through use of our Legitimate Interests

Broadly speaking Legitimate Interests means that we can process your personal
information if:

 * We have a genuine and legitimate reason and
 * We are not harming any of your rights, freedoms and interests
 * We’ve considered that you would not find such processing unreasonable

For example, via a variety of mechanisms we may collect and store business
contact data about you if you are a professionally relevant contact for our
services, or that of our customers who use our MTD email marketing campaign tool
to send you marketing about their products/services and you are employed in a UK
organization which is separate legal entity. Your data will only be used where
the product or service might be relevant to you in your professional capacity.

However, we want to respect your wishes about how and if you are contacted. On
occasion we will contact you to verify your position, check how you would prefer
to receive direct marketing, whether by post, by phone or by email and to remind
you of your rights via our any updates to our privacy statement.

You may of course tell us you do not wish to be contacted at all, and we will
respect your wishes, add you to a suppression list, and not contact you again.

Further information explaining how we define our Legitimate Interests

We have conducted a Legitimate Interest Test which included the following
considerations:

 * The relationship between ourselves and you as the data subject
 * Our Purpose/Necessity to use Legitimate Interests and other alternatives
 * The PECR regulation and it’s relevance to B2B marketing
 * The sensitivity of the personal data that we have collected and processed
 * The reasonable expectations we think you have in your professional role
 * Whether you’d be likely to object to the processing or find it intrusive
 * The safeguards we have in place to minimise any risks to your privacy
 * That a mechanism exists via which you can challenge out assessment
 * We will always ensure there is an opt-out / ability to object

The Purpose Test

We consider that we have a legitimate interest in carrying out a business in
favour of the well-being of all our employees and shareholders. This is
enshrined in the EU Charter of Human Rights – Article 16 – Freedom to conduct a
business.

For prospective customers, identified as working for separate legal entities
(“users of an electronic network”) and whom we consider are professionally
relevant post holders; we consider we have a legitimate interest to process your
data for the purposes of marketing of products and services. This purpose is
supported by Recital 47 of the GDPR which states that:

“The processing of personal data for direct marketing purposes may be regarded
as carried out for a legitimate interest”

We believe that professionals rely on being kept up to date about new products
or services to help them achieve their business objectives and direct marketing
is generally seen as an important tool to facilitate this.

However, we will always respect your wishes, if you’re the recipient of our
marketing.

The Balancing Test

A balancing test has been undertaken to compare our legitimates interests and
the interests or fundamental rights and freedoms of prospective customers who
require protection of their personal data,

We will only process personal data if we have determined that our services are
‘professionally relevant’ to you and your organisation.  Material that we send
to you may be relevant based on your profile, because of the type, size or
location of the organisation that you work in, or because you are the right
post-holder for a certain set of decisions based on factors like your role,
seniority, and responsibilities.

We believe that the recipients of our marketing have a reasonable expectation
that we as a Controller will process their Personal Data.

The data we may hold on recipients originates from primary research by our
telephone research team, publically available material held on websites, events
we have jointly attended, personal data we have captured via business cards or
similar interaction; or referrals from other organisations, data captured via
visiting our websites or via subscribing to and opening our B2B emails.

The personal data we hold is strictly limited to the organisational name,
contact name, email addresses, telephone numbers, postal addresses,
sector/industry classification of companies that are separate legal entities. It
is never sensitive data, and in most cases would likely exist in the public
domain.

Our assessment has taken into consideration the Information Security Management
System we are currently implementing and it also recognises the safeguards we
have put in place through the implementation of the British Standard
BS10012:2017 – Personal Information Management Framework delivering readiness to
GDPR.

Outputs of this framework include, but are not limited to:

 * Data Protection Impact Assessments supporting ‘privacy by design and default’
 * Data Minimisation as a guiding principle
 * Pseudonymization where appropriate
 * Adding extra transparency through regularly updated privacy notices & fair
   processing notices
 * Regular Internal Audits and Continual Improvement
 * Encryption ‘at rest’ and ‘in transit’ where appropriate
 * Multi-factor authentication and Access Control
 * Strict data retention controls
 * Regular Staff Training and Awareness of Data Privacy Regulation
 * Other technical security methods used to protect data
 * An appointment of an independent Data Protection Officer

Our conclusion is the likelihood of impact and the severity of negative impact
or distress of the data processing we undertake is negligible.

Contractual Processing

Where the processing is based on Article 6(1) par. b – necessary for the
performance of a contract to which you are a party, or in order to take steps at
your request prior to entering into a contract; we’ll process your information
as customers to enable us to contact you and fulfil the services you have
requested.

The information we’re likely to hold is your name, job title, your work postal
address, work email address, and telephone number. Your personal information is
only disclosed to our employees and sub-contractors who have met out due
diligence procedures.

The legal basis for processing your data is ‘fulfilling a contract’ whilst we
are your supplier. When you are no longer an active customer, it will be
our ‘legitimate interest’ because you may want to order from us again. We
benefit from solving communication challenges and we’d like to help you in the
future. The same applies to such processing operations which are necessary for
carrying out pre-contractual measures, for example in the case of inquiries
concerning our products or services

Processing using Consent

There are certain circumstances, where we may need consent from you in order to
process your data and we recognise the above options are not the only lawful
grounds for processing data.  If this is the case we will ensure that the
consent that you provide is by a clear affirmative act establishing a freely
given, specific, informed and unambiguous indication of your agreement to the
processing of personal data relating to you.

You may withdraw consent at any time by either unsubscribing (via the
Unsubscribe link on the footer of all network emails).

Please note that we may still be required to send you transaction or service
emails relating to any services of ours that you have purchased or enquired
about.

Email Marketing

In relation to any email marketing that you may receive from us, either at your
request or in any other circumstances, we may monitor whether you open and/or
click on any links in such emails and we uses various tracking techniques such
as web beacons to measure the effectiveness of our email campaigns, ascertain
your static IP address and tailor our communications to your interests

You may unsubscribe from emails at any time by clicking the relevant link in
those emails. We conduct this email marketing in adherence with the Privacy and
Electronic Communications Regulation which derive from the European Directive
2002/58/EC.

This allows for B2B marketing on an opt-out basis in so long as a lawful means
of processing under GDPR has been established.

Our website uses cookies, here’s what they do and how you can stop them if you
wish

You do not have to give us any personal data in order to use this website.
However you may provide us with personal data by completing forms on this
website or by contacting us by telephone or email.

When you visit this website, we will automatically collect the internet protocol
(IP) address of the device used by you to visit this website as well as the type
of the device, browser version and time zone setting. This will enable us to
identify you as a unique user for analytical purposes and to optimise our
website for your device. This data does not directly allow us to, and we will
not attempt to use this data to, identify individuals

Cookies

This website uses small text files, called cookies, which are automatically
stored on your device when you access and use certain features of this website.

As cookies are unique, we can use them to distinguish you from other users. To
find out more about cookies, how to refuse them and how to change your device’s
cookie settings, you should visit All About Cookies. Please note that if you
refuse to accept cookies or change your device’s cookie settings, you may not be
able to use all of this website’s features.

Data collected from the use of cookies does not allow us to, and we will not
attempt to use this data to, identify you in a personal capacity or individual
subscriber.

The categories of cookies used by this website are as follows:

 * Strictly necessary cookies – cookies that are required for the operation of
   this website and its features, such as accessing secure areas of this website
 * Performance cookies – cookies that allow us to recognise and new and
   returning users to this website and to track how they navigate around it to
   help us improve this website

The cookies used by this website are as follows:

MTD CNC

Source Cookie Description MTD CNC _mu This is a unique id that identifies a
visitor. This allows us to see what pages are most popular and where our
visitors are coming from. Magazine This keeps track of whether the user has
closed the magazine pop-up. In order not to interrupt the user’s viewing
experience. Policy This keeps track of whether the user has closed the cookie
policy pop-up. In order not to interrupt the user’s viewing experience.
productSelection This stores the previously selected product’s author id. This
allows us to remember your last viewed product, in order to make your user
experience better. productSelectionName This stores the previously selected
product’s name. This allows us to remember your last viewed product, in order to
make your user experience better. productSelectionText This stores the
previously selected product’s description. This allows us to remember your last
viewed product, in order to make your user experience better.

 

Google Analytics

Source Cookie Description Google Analytics __utma This cookie creates a unique
ID when a new visitor browses our website. It helps us to assess the number of
new visitors to our site, and also identify whether we are receiving repeat
visitors, too. __utmb These two cookies help us measure a visitor’s session,
giving us data on what time visitors arrive and how long they spend browsing our
website. __utmc __utmz This cookie gives us information about how a visitor got
to our site (e.g. Google Search, referral site, social media, direct URL, etc.)
and also which pages they viewed after they arrived. Double Click This cookie
collects anonymised Ad Views, Analytics, Browser Information, Date/Time,
Demographic Data, Hardware/Software Type, Internet Service Provider, Interaction
Data, Page Views, Serving Domains) Audiences This cookie collects anonymous data
(Ad Views, Analytics, Browser Information, Cookie Data , Date/Time, Demographic
Data, Hardware/Software Type, Internet Service Provider, Interaction Data , Page
Views , Serving Domains) Add This Add This Provides statistics about bookmarking
and sharing activity of users

These cookies are used by the Google Analytics service to identify unique
visitors to this website, where they came from, which pages they visit and how
long they spend on it.

Further information can be found in the Google Privacy Policy.

Most browsers allow you to refuse to accept cookies; for example:

 * In Internet Explorer (version 11) you can block cookies using the cookie
   handling override settings available by clicking “Tools”, “Internet Options”,
   “Privacy” and then “Advanced”;
 * In Firefox (version 39) you can block all cookies by clicking “Tools”,
   “Options”, “Privacy”, selecting “Use custom settings for history” from the
   drop-down menu, and unticking “Accept cookies from sites”; and
 * In Chrome (version 44), you can block all cookies by accessing the “Customise
   and control” menu, and clicking “Settings”, “Show advanced settings” and
   “Content settings”, and then selecting “Block sites from setting any data”
   under the “Cookies” heading.Blocking all cookies will have a negative impact
   upon the usability of many websites. If you block cookies, you will not be
   able to use all the features on our website.You can also delete cookies
   already stored on your computer; for example:
 * In Internet Explorer (version 11), you must manually delete cookie files (you
   can find instructions for doing so
   at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
 * In Firefox (version 39), you can delete cookies by clicking “Tools”,
   “Options” and “Privacy”, then selecting “Use custom settings for history”
   from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove
   All Cookies”; and
 *  In Chrome (version 44), you can delete all cookies by accessing the
   “Customise and control” menu, and clicking “Settings”, “Show advanced
   settings” and “Clear browsing data”, and then selecting “Cookies and other
   site and plug-in data” before clicking “Clear browsing data”.

Access to your personal data and rights to correct, restrict or delete that data

At any point while we are in possession of or processing your personal data,
you, the data subject, have the following rights:

 * Right of access – you have the right to request a copy of the information
   that we hold about you free of charge
 * Right of rectification – you have a right to correct data that we hold about
   you that is inaccurate or incomplete.
 * Right to be forgotten – in certain circumstances you can ask for the data we
   hold about you to be erased from our records.
 * Right to restriction of processing – where certain conditions apply to have a
   right to restrict the processing.
 * Right of portability – you have the right to have the data we hold about you
   transferred to another organisation.
 * Right to object – you have the right to object to certain types of processing
   such as direct marketing.
 * Right to object to automated processing, including profiling – you also have
   the right to be subject to the legal effects of automated processing or
   profiling.
 * Right to judicial review: in the event that MemberWise refuses your request
   under rights of access, we will provide you with a reason as to why. You have
   the right to complain as outlined below

All of the above requests will be forwarded on should there be a third party
involved in the processing of your personal data.


OTHER WEBSITES

On occasion our website will contain links to other websites. This privacy
policy only applies to the MTD website – http://www.mtdcnc.com. When you link to
other websites you should read their own privacy policies.


CHANGES TO OUR PRIVACY POLICY

We keep our privacy policy under regular review and we will place any updates on
this web page. This privacy policy was last updated on 16th May 2018.


HOW LONG WE KEEP YOUR DATA

Any information provided by you will be retained for as long as necessary in
connection with the purposes for which it was provided, for example, to respond
to your enquiry or in the case of customer data, for three years after your last
invoice to us.  After which, we will either delete your personal data, or keep
it because you have asked us to.

In respect of any contact information stored within our customer relationship
management (CRM) system, we will delete your details upon request and if we have
not had any further communication with you within a period of three years.

Any information collected about you or your activity through the use of cookies,
will be retained for the time periods set out in the above table.

In any case, once we have processed any information about you in connection with
the purposes for which it was provided or collected, we will securely delete or
anonymise (to the extent such information was capable of identifying you in the
first instance) such information upon expiry of the above time periods.

How to contact us in regards to your rights or to make a complaint

In the event that you wish to make a complaint about how your personal data is
being processed by us (or any of our 3rd parties), or how your complaint has
been handled, you have the right to lodge a complaint with our Data Protection
Officer and with the ICO.

Contact Name: The Data Protection Officer Address line 1: MTD Ebusiness Ltd
Address line 2: Bedford Heights Address line 3: Manton Lane Post Code MK41 7PH
Email: Dataprotection@mtdcnc.com



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