MASHIE APP PRIVACY POLICY
INTRODUCTION
MASHIE 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 download and use our mobile application (regardless of where you access it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1) IMPORTANT INFORMATION AND WHO WE ARE
1.1) PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how MASHIE collects and processes your personal data through your use of this application, including any data you may provide through this mobile application when you sign up to use our reminder service, vehicle statistics data, marketing and related communications.
This mobile application is not intended for persons under 16 and we do not 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 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.
1.2) CONTROLLER
Coinbridge Limited (MASHIE) is the data controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
1.3) PROCESSOR
Coinbridge Limited (MASHIE) and your nominated entity are joint data processors and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
1.4) CONTACT DETAILS
Our full details are: Our full details are: Coinbridge Limited trading as MASHIE, at 7 The Hayloft, Far Peak, Northleach, Gloucestershire, United Kingdom, GL54 3AP
Full name of legal entities: Coinbridge Limited
Data Protection Email address: [email protected]
Postal address: FAO Data Protection Coinbridge Limited, 7 The Hayloft, Far Peak, Northleach, Gloucestershire, United Kingdom, GL54 3AP
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.
1.5) CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 13th November 2023 and historic versions can be obtained by contacting customer services.
The data protection law in the UK changed 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.
1.6) THIRD-PARTY LINKS
This mobile application includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect 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 mobile application, we encourage you to read the privacy notice of every website you visit.
2) THE DATA WE COLLECT ABOUT YOU
2.1) PERSONAL DATA
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:
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 mobile application 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). Nor do we collect any information about criminal convictions and offences.
2.2) 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 access to the app). 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?
3.1) DATA COLLECTION
We use different methods to collect data from and about you including through:
4) HOW WE USE YOUR PERSONAL DATA
4.1) DATA USAGE
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:
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 push notification, text message or email.
4.2) CONSENT WITHDRAW AND ACCOUNT DELETION
You have the right to withdraw consent to marketing at any time by updating your preferences in Settings on the mobile application, opting out using links provided in communications received or emailing us at [email protected] to delete your account.
4.3) PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, 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 customer services 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.
MASHIE 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 download and use our mobile application (regardless of where you access it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1) IMPORTANT INFORMATION AND WHO WE ARE
1.1) PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how MASHIE collects and processes your personal data through your use of this application, including any data you may provide through this mobile application when you sign up to use our reminder service, vehicle statistics data, marketing and related communications.
This mobile application is not intended for persons under 16 and we do not 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 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.
1.2) CONTROLLER
Coinbridge Limited (MASHIE) is the data controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
1.3) PROCESSOR
Coinbridge Limited (MASHIE) and your nominated entity are joint data processors and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
1.4) CONTACT DETAILS
Our full details are: Our full details are: Coinbridge Limited trading as MASHIE, at 7 The Hayloft, Far Peak, Northleach, Gloucestershire, United Kingdom, GL54 3AP
Full name of legal entities: Coinbridge Limited
Data Protection Email address: [email protected]
Postal address: FAO Data Protection Coinbridge Limited, 7 The Hayloft, Far Peak, Northleach, Gloucestershire, United Kingdom, GL54 3AP
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.
1.5) CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 13th November 2023 and historic versions can be obtained by contacting customer services.
The data protection law in the UK changed 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.
1.6) THIRD-PARTY LINKS
This mobile application includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect 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 mobile application, we encourage you to read the privacy notice of every website you visit.
2) THE DATA WE COLLECT ABOUT YOU
2.1) PERSONAL DATA
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 and last name.
- Contact Data
- includes email address and mobile number.
- Transaction Data
- includes details of the reminder and marketing services you used on The App.
- 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 mobile application.
- Profile Data
- includes your password, reminder and marketing services used.
- Usage Data
- includes information about how you use our mobile application, products and services.
- Marketing and Communications Data
- includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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 mobile application 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). Nor do we collect any information about criminal convictions and offences.
2.2) 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 access to the app). 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?
3.1) DATA COLLECTION
We use different methods to collect data from and about you 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:
- Downloaded the mobile application;
- Register for an account on the mobile application;
- Request marketing (motoring related news, offers and messages) to be sent to you;
- 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:
- Indirect interactions.
- Your entity may give us your Identity and Contact Data following interactions with them via post, phone, email or otherwise.
- Automated technologies or interactions.
- As you interact with our mobile application, 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. We may also receive Technical Data about you if you visit other MASHIE websites employing our cookies.
- Third parties or publicly available sources.
- We may receive personal data about you from various third parties and public sources:
- Device & Operating system manufacturers:
- Google (base outside the EU)
- Apple (based outside the EU)
- Analytics providers:
- Mailgun (based in the EU)
- Apple (based outside the EU)
- Google (based outside the EU)
- Device & Operating system manufacturers:
- We may receive personal data about you from various third parties and public sources:
4) HOW WE USE YOUR PERSONAL DATA
4.1) DATA USAGE
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, or your entity) 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 push notification, text message or email.
4.2) CONSENT WITHDRAW AND ACCOUNT DELETION
You have the right to withdraw consent to marketing at any time by updating your preferences in Settings on the mobile application, opting out using links provided in communications received or emailing us at [email protected] to delete your account.
4.3) PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, 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 customer services 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: Providing notifications Providing Tee-Time, Fourball and other booking services |
(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications |
Performance of a contract with you |
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy |
(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 administer and protect our business and this mobile application (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 mobile application 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 mobile application, 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 mobile application 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) |
4.4) MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
4.5) 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 elected to on the mobile application.
4.6) PROMOTIONAL OFFERS FROM MASHIE
MASHIE may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what they think you may want or need, or what may be of interest to you. This is how they decide which products, services and offers may be relevant for you (they call this marketing).
You will receive marketing communications from MASHIE if you have elected to on the mobile application.
4.7) THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company outside MASHIE for marketing purposes.
4.8) OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by logging into the mobile application and checking or unchecking relevant boxes to adjust your marketing preferences.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of another transaction.
4.9) COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when mobile applications set or access cookies. If you disable or refuse cookies, please note that some parts of this mobile application may become inaccessible or not function properly.
4.10) 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 contact customer services.
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
5.1) DATA DISCLOSURE
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above:
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
- The mobile application enables any communication preferences and types of message to be updated at anytime.
- Your account can be deleted at anytime by emailing us at [email protected].
4.5) 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 elected to on the mobile application.
4.6) PROMOTIONAL OFFERS FROM MASHIE
MASHIE may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what they think you may want or need, or what may be of interest to you. This is how they decide which products, services and offers may be relevant for you (they call this marketing).
You will receive marketing communications from MASHIE if you have elected to on the mobile application.
4.7) THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company outside MASHIE for marketing purposes.
4.8) OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by logging into the mobile application and checking or unchecking relevant boxes to adjust your marketing preferences.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of another transaction.
4.9) COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when mobile applications set or access cookies. If you disable or refuse cookies, please note that some parts of this mobile application may become inaccessible or not function properly.
4.10) 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 contact customer services.
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
5.1) DATA DISCLOSURE
We may have to share your 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.
- The following specific third-parties:
Specific Third Party |
Reason for sharing |
Digital Ocean |
Hosting Mobile Application service |
Mailgun |
Send agreed email communications, including purchase information, reminders, booking details, communications and bookings |
Entity |
Providing related marketing content, and account management for linked customers who have agreed to these communications |
Google |
Send agreed PUSH communications, including purchase information, reminders, booking details, communications and bookings |
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
6.1) INTERNATIONAL DATA TRANSFER
We share your personal data within MASHIE and specified third parties. This will not involve transferring your data outside the European Economic Area (EEA) or the UK.
7) DATA SECURITY
7.1) SECURITY MEASURES
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
8.1) 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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting customer services.
By law we have to keep basic information about our customers (including 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 Request erasure below for further information.
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
9.1) REQUESTS, RIGHTS & OBJECTIONS
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
If you wish to exercise any of the rights set out above, please contact customer services.
9.2) 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.
9.3) 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.
9.4) 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
10.1) LAWFUL BASIS
10.2) THIRD PARTIES:
10.3) YOUR LEGAL RIGHTS
You have the right to:
6) INTERNATIONAL TRANSFERS
6.1) INTERNATIONAL DATA TRANSFER
We share your personal data within MASHIE and specified third parties. This will not involve transferring your data outside the European Economic Area (EEA) or the UK.
7) DATA SECURITY
7.1) SECURITY MEASURES
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
8.1) 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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting customer services.
By law we have to keep basic information about our customers (including 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 Request erasure below for further information.
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
9.1) REQUESTS, RIGHTS & OBJECTIONS
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact customer services.
9.2) 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.
9.3) 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.
9.4) 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
10.1) 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/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 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 contact customer services.
- 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.
- Data Controller
- means an entity who (either alone or jointly or in common with other entities) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
- Data Processor
- means an entitiy who (either alone or jointly or in common with other entities) engages in personal data 'processing' on behalf of the controller.
- Personal Data
- means any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
- Processing
- in relation to information or data, means obtaining, recording or holding the information or data or carrying out any operation or set of operations on the information or data, including:
- (a) organisation, adaptation or alteration of the information or data,
- (b) retrieval, consultation or use of the information or data,
- (c) disclosure of the information or data by transmission, dissemination or otherwise making available, or
- (d) alignment, combination, blocking, erasure or destruction of the information or data.
- in relation to information or data, means obtaining, recording or holding the information or data or carrying out any operation or set of operations on the information or data, including:
- Special Category Data
- is broadly similar to the concept of sensitive personal data under the 1998 Data Protection Act. The requirement to identify a specific condition for processing this type of data is also very similar.This is because special category data is more sensitive, and so needs more protection.For example, Special Category Data is information about an individual’s: race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sex life; or sexual orientation.
10.2) THIRD PARTIES:
- INTERNAL THIRD PARTIES
- are other companies in the Coinbridge Limited (Trading as MASHIE) group of companies acting as processors and who are based in the United Kingdom and provide IT and system administration services and undertake leadership reporting.
- EXTERNAL THIRD PARTIES
- are service providers acting as a joint controller and processors based in the United Kingdom who provide:
- IT and system administration services
- professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom 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.
- are service providers acting as a joint controller and processors based in the United Kingdom who provide:
10.3) 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.
MASHIECLUB.CO.UK PRIVACY POLICY
This policy details the tools, information and the way we use data about activity on our website.
We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this privacy statement.
Our Privacy Policy may be updated from time to time. Please check this page to ensure that you are happy with any changes. This policy is effective from 01/10/2017.
COOKIES AND GOOGLE ANALYTICS
We use cookies on our site to enable Google Analytics, a web analytics tool, to help us understand how visitors engage with our website. We may use Google Analytics to collect information about your computer, such as your operating system and browser type, in order to create reports. Google Analytics collects statistical data anonymously, reporting website trends without identifying individual visitors.
GOOGLE ADVERTISING FEATURES
We make use of some Google Advertising Features such as Remarketing with Google Analytics, Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting. This enables us to collect data about our website traffic via Google advertising cookies and identifiers, in addition to data collected through a standard Google Analytics implementation.
If you wish, you can opt out of Google Analytics without affecting how you visit our site. For advice on opting across all websites you use, visit this Google page.
DATA ENTRY
We may ask you to provide personal contact information, such as that used during ordering, requesting information or subscribing to our newsletters. This information will be used specifically for the task at hand. Contact details entered during the ordering process will automatically be stored on our website database. We may also enter any contact details into our secure customer relationship management database and email marketing provider so that we can provide you with the best service in the future.
PAYMENT INFORMATION
Please note that we do not store any customer credit/debit card information. This is stored separately by our payment gateway, Stripe. Stripe is a leading provider of payment processing technology who accept payment from all major cards across the world, on web or mobile applications. For further information on Stripe, view their About page here, or their Privacy Policy here.
LINKS TO OTHER WEBSITES
Our website contains links to other websites. Although we believe these links to be useful, we do not have any responsibility or control over the content on those websites. We cannot therefore be responsible for the protection and privacy of any information which you provide whilst visiting such sites. External sites are not governed by this Policy.
CONTROLLING YOUR PERSONAL INFORMATION
You may choose to restrict the collection or use of your personal information in the following ways:
You may request details of personal information which we hold about you under the Data Protection Act 1998. If you would like a copy of the information held on you please write to us, or email us. (Details found at the bottom of this page). If you believe that any information we are holding on you is incorrect or incomplete, please write to us, or email us as soon as possible. We will promptly correct any information found to be incorrect.
If you have any questions about the way in which we (MASHIE) collects, handles and stores data about you or any online activity via this website, please contact us.
We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this privacy statement.
Our Privacy Policy may be updated from time to time. Please check this page to ensure that you are happy with any changes. This policy is effective from 01/10/2017.
COOKIES AND GOOGLE ANALYTICS
We use cookies on our site to enable Google Analytics, a web analytics tool, to help us understand how visitors engage with our website. We may use Google Analytics to collect information about your computer, such as your operating system and browser type, in order to create reports. Google Analytics collects statistical data anonymously, reporting website trends without identifying individual visitors.
GOOGLE ADVERTISING FEATURES
We make use of some Google Advertising Features such as Remarketing with Google Analytics, Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting. This enables us to collect data about our website traffic via Google advertising cookies and identifiers, in addition to data collected through a standard Google Analytics implementation.
If you wish, you can opt out of Google Analytics without affecting how you visit our site. For advice on opting across all websites you use, visit this Google page.
DATA ENTRY
We may ask you to provide personal contact information, such as that used during ordering, requesting information or subscribing to our newsletters. This information will be used specifically for the task at hand. Contact details entered during the ordering process will automatically be stored on our website database. We may also enter any contact details into our secure customer relationship management database and email marketing provider so that we can provide you with the best service in the future.
PAYMENT INFORMATION
Please note that we do not store any customer credit/debit card information. This is stored separately by our payment gateway, Stripe. Stripe is a leading provider of payment processing technology who accept payment from all major cards across the world, on web or mobile applications. For further information on Stripe, view their About page here, or their Privacy Policy here.
LINKS TO OTHER WEBSITES
Our website contains links to other websites. Although we believe these links to be useful, we do not have any responsibility or control over the content on those websites. We cannot therefore be responsible for the protection and privacy of any information which you provide whilst visiting such sites. External sites are not governed by this Policy.
CONTROLLING YOUR PERSONAL INFORMATION
You may choose to restrict the collection or use of your personal information in the following ways:
- Whenever you are asked to fill in a form on the website, tick the box to indicate that you do want to opt in for direct marketing.
- If you have previously agreed to us using your information for direct marketing purposes, you may opt-out of this by clicking the link at the bottom of our emails, writing to us, or emailing us. (Details found at the bottom of this page).
You may request details of personal information which we hold about you under the Data Protection Act 1998. If you would like a copy of the information held on you please write to us, or email us. (Details found at the bottom of this page). If you believe that any information we are holding on you is incorrect or incomplete, please write to us, or email us as soon as possible. We will promptly correct any information found to be incorrect.
If you have any questions about the way in which we (MASHIE) collects, handles and stores data about you or any online activity via this website, please contact us.