This is the privacy policy for the www.millgens.com website which is owned and operated by MillGens Limited, a company registered in England under number 12248511 with our registered office address at 47 Marylebone Lane, London, W1U 2NT (“we”, “our” and “us” in this policy).
We recognise the importance of respecting and protecting your personal data (information) and yet in order to be able to continue to provide you with the level of service you expect from us we need to collect, process and share a certain amount of information about you. In this document, we explain what information we’re likely to hold, how we collect it and how we will use or share it. It also explains your rights and how to contact us or the ICO in the event you have a complaint. Our commitment to you is that we will continue to treat your personal data fairly and legally and with the discretion and respect you’d expect from us.
MillGens Limited is the data controller of your information. This means that we exercise some judgment in determining how and why to process the information you share with us. We may share your information with the other members of our group of companies. If you have questions about how we process your information that aren’t answered in this policy, we invite you to get in touch with us at privacy@millgens.com.
The main reasons why we collect and use data about visitors to our website are:
- To show you content that is relevant to you and to improve your experience on our site
- To provide the services you express an interest in or register for, such as membership
- To carry out marketing analysis and send you communications when we have your permission, or when permitted by law
- To enable us to show third party brand content on our site.
What information we collect and how we use it
Here we summarise the information we collect, why and how we use it and who we share it with. We will keep your data secure and won’t sell your personal data to third parties – ever. We only use your personal data to help us provide you with a great service, and tailor the information we share with you to help make it relevant, useful and timely. We will not collect special categories of data – such as information about your race, political opinions, religion, health or sexual orientation – unless you have chosen to provide that information to us.
All your information falls into one or more of the following categories:
To provide you with the services you are interested in and/or have requested from us
What
Your name, billing address and payment information, phone number and email address
From Whom
From you
Lawful Basis
The contract between us
With Whom
The people at our office HQ, those we have engaged to develop our website and third parties who support us in processing payments
To analyse your use of our website
What
Your IP address (a numerical code to identify your device and which can provide geographical location information), browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use and other technology on the devices you use to access our websites, • details of your devices, for example, the unique device ID, unique advertising ID and browsers used to access our content
From Whom
From cookies (or similar technology), our analytics packages (including, but not limited to Google Analytics)
Lawful Basis
Our legitimate interests, namely to monitor and improve our website and the services we provide to you
With Whom
The people at our office HQ, those we have engaged to develop our website and those third party brands we have partnered with
To contact you about the services you have expressed an interest in, relevant offers, information and messages
What
Your name, email address, postal address, phone number or marketing preferences (update them here)
For Whom
From you and from our records of your transactions and interests
Lawful Basis
The contract between us for your orders; our legitimate interests for direct marketing communications
With Whom
The people at our office HQ, and those we have engaged to support us with our membership
To provide clarification, resolve issues or market relevant services to you
What
Your name, email address, postal address or phone number
From Whom
From you and from our records of your interests
Lawful Basis
The contract between us and to ensure that we respond to your enquiry appropriately
With Whom
The people at our office HQ [and those third party brands we have partnered with]
To provide you with services tailored to your preferences
What
Your name, username, password, email address, unique ID number we assign to you
From Whom
From you when you create your profile
Lawful Basis
The contract between us
With Whom
The people at our office HQ and those we have engaged to support us with our website
We may process any of your information identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific disclosures of your information set out in this Section, we may disclose your information with law enforcement and fraud prevention agencies, so we can help tackle fraud or where such disclosure is necessary for compliance with a legal obligation to which we are subject, in order to protect your vital interests or the vital interests of another natural person, or in connection with the establishment, exercise or defence of legal claims, whether in court or not.
We may also process any of your information where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
Our website may include 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 website, we encourage you to read the privacy notice of every website you visit.
By interacting with us on social media (such as joining or following our official group or page, liking or retweeting), you are consenting to our interaction with you on social media and the processing of your information accessed on social media. Your name, user profile, age, preferences, choices and opinions in relation to the topic or subject matter of the relevant social media page, your photos and other images and your videos may be collected when you interact with us on social media. Please contact us if at any time you wish us to stop interacting with you on social media or using any of your information obtained from social media.
Please do not supply us with any other person’s personal information, unless we prompt you to do so. If you do share other people’s details with us, please ensure you have their prior authorisation.
Transferring your personal information outside of the European Economic Area (“EEA”)
The information you share with us is stored and hosted in the European Economic Area (EEA). We will only transfer your personal data to a country outside the list of countries approved by the EU Commission as having appropriate safeguards for data transfers where you are based in such a country. If we need to make an international transfer of information for such purposes, we will use standard data protection contract clauses which have been approved by the European Commission. These are designed to re-create protections equivalent to those enjoyed in the EEA.
How long we hold on to your information
We only hold on to information for as long as we need to. How long will depend on the kind of information it is and why we need it.
To determine the appropriate retention period for information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of your information, the purposes for which we process the information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where the lawful basis of our processing is based on your consent we will retain the personal data for as long as we have your consent to do so.
For example, if you have applied for membership registration on our website but not purchased a membership from us, the length of time we will hold on to your information is dependent on whether you have opted into our other marketing communications, such as our newsletters. If you have opted in, we will hold on to your information for 24 months from your application; if you have not opted in, we will retain your information for six months from your application.
Whilst you are an active user (which means you have purchased a membership package from us) we will hold on to your information for as long as needed to give you the best possible service; financial information we will hold for 7 years.
In certain circumstances we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, to resolve disputes and enforce our agreements.
Your rights
Access
You have the right to request a copy of the personal data we hold about you, but we will not include anything that compromise another person’s confidentiality or intellectual property. We’ll aim to send this to you within 1 month of your request. If we can’t do this, we’ll let you know within the 1 month
Rectification
You have the right to ask us to correct any mistakes in your personal data
To be forgotten
You have the right to require us to delete your personal data in certain situations
Restriction of processing
You have the right to require us to restrict processing of your personal data in certain circumstances for example, if you don’t think it’s accurate
Data portability
You have the right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations
To object
The right to object:
- at any time to your personal data being processed for direct marketing (including profiling) by emailing privacy@millgens.com
- in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests
Automated decision-making
You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time.
Right to complain
In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at privacy@millgens.com and we will endeavour to resolve your query as soon as possible. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to complain to a supervisory authority which in the UK is the Information Commissioner’s Office. You can contact them on https://ico.org.uk/.
Securing your information
At MillGens Limited, all of the information we hold is stored on secure servers located in the in the cloud. The key solutions we use are well- known, global businesses that are GDPR compliant and secure. We may use other smaller, local service providers from time to time and in these cases, will ensure that they are bound by the GDPR and obligations of confidentiality.
We have put in place appropriate security measures as well as a security policy to ensure that everyone does their bit to keep all data – not just personal data, secure and confidential. Despite this, nothing can be 100% secure and we will notify you and the ICO of a suspected data security breach where we are legally required to do so.
About Changes
This privacy notice was published on 15 March 2020.
We may change this privacy notice from time to time. Where these changes are substantial or have an impact to your rights, we will let you know. You should check this page occasionally to ensure that you are happy with any changes to this policy.
Cookie Policy
What is a cookie?
A cookie is a small file that can be placed on your device that allows us to recognise and remember you. It is sent to your browser and stored on your computer’s hard drive or tablet or mobile device. When you visit our site, we may collect information from you automatically through cookies or similar technology.
How do we use cookies?
We use cookies in a range of ways to improve your experience on our site, including
- Keeping you signed in
- Understanding how you use our site
- Showing you MillGens editorial content that is relevant to you
- Working with partners to serve you relevant third party editorial content
Other organisations also collect user information on our site through cookies, tags and pixels. Tags and pixels, also known as web beacons, are similar to cookies but are collected through embedded images.
Using cookies and other technology allows other organisations to help us to analyse how our site is being used, measure the number of visitors to the site, and display advertising.
Cookies that are used by MillGens are referred to as “first-party cookies” and those that are used by our partners are “third-party cookies”. Because of how cookies work, our website cannot access third-party cookies; nor can other organisations access the data in the cookies we use on our website. There are more details about both in the following sections.
What types of cookies do we use?
We use four types of cookies, which we describe in this section.
Performance – cookies which measure how often you visit our site and how you use them. We use this information to get a better sense of how our users engage with our editorial content and to improve our site so that users have a better experience. For example, we collect information about which of our pages are most frequently visited, and by which types of users. We also use third-party cookies to help with performance. For example, the Google Analytics cookie gives us information such as your journey between pages and whether you have downloaded anything (details of how to opt out of it are below).
Functionality – cookies that are used to recognise you and remember your preferences or settings when you return to our site, so that we can provide you with a more personalised experience. A mix of first-party and third-party cookies are used.
Essential – cookies that are essential to provide you with services you have requested. If you set your browser to block these cookies, then these functions and services will not work for you. In particular, we won’t be able to save your preferences about cookies.
Third party brand partners – cookies that are used to collect information about your visit to our site, the content you have viewed, the links you have followed and information about your browser, device and your IP address.