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Combined Data Protection Notice & Privacy Policy

Background

Malaby Holdings Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and employees and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

  1. Information About Us
    Company name: Malaby Holdings Ltd
    Limited Company registered in England under company number 00105189
    Registered Address: Bore Hill Farm Biodigester, Deverill Road, Warminster, BA12 8FB VAT number: 115101282
    Controller: Toby Minter
    Processor: Toby Minter
    Email address: tobyminter@malabymartin.com
    Telephone number: 07771 822811
    Postal Address: Bore Hill Farm Biodigester, Deverill Road, Warminster, BA12 8FB
  2. What Does This Notice and Policy Cover?
    This Data Protection Notice and Privacy Policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
  3. What is our legal basis for processing your information?
    We will process your data on the legal basis of your consent and contractual obligations.
  4. What is Personal Data?
    Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

    Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

    The personal data that we use is set out in Part 6, below.

  5. What Are My Rights?
    Under the GDPR, you have the following rights, which we will always work to uphold:

    a)  The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12.

    b)  The right to access the personal data we hold about you. Part 11 will tell you how to do this.

    c)  The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.

    d)  The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have (subject to other legal requirements for retention of information e.g. statutory keeping of employment records etc). Please contact us using the details in Part 12 to find out more.

    e)  The right to restrict (i.e. prevent) the processing of your personal data.

    f)  The right to object to us using your personal data for a particular purpose or purposes.

    g)  The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means.

    h)  Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

    i)  The right to be notified of a data breach within 72 hours of a breach occurring.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

  1. What Personal Data Do We Collect?
    We may collect some or all of the following personal data (this may vary according to your

    relationship with us):

    • Name
    • Date of birth
    • Gender
    • Address
    • Email address
    • Telephone number
    • Business name
    • Job title
    • Profession
    • Payment information
  2. How Do We Use Your Personal Data?
    Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

    • Providing and managing your account.
    • Providing and managing your employment status (if relevant). GDPR Privacy Policy MH300321
  • Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
  • Communicating with you. This may include responding to emails or calls from you.
  • Supplying you with information by email unless you have unsubscribed or opted-out

    With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

  1. How Long Will We Keep Your Personal Data?
    We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for an unspecified period or until you notify us that you do not want us to hold your personal data.
  2. How and Where Do We Store or Transfer Your Personal Data?
    We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

    The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:

    • All marketing emails are sent via bcc.
    • All hard copy personal information is stored in locked filing cabinets.
    • All company computers have password security.
  3. Do We Share Your Personal Data?
    We will not share any of your personal data with any third parties for any purposes, subject to one

    important exception.

    In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

  4. How Can you Access Your Personal Data?
    If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

    All subject access requests should be made in writing and sent to the email or postal address shown in Part 12.

    There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’, as defined in the GDPR regulations, (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

    We will respond to your subject access request within 30 days of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of 90 days from the date we receive your request. You will be kept fully informed of our progress.

  1. How You Contact Us?
    To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

    Email address: info@malabymartin.com
    Telephone number: 07771 822811
    Postal Address: Bore Hill Farm Biodigester, Deverill Road, Warminster, BA12 8FB

  2. Changes to this Privacy Notice

    We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or business in a way that affects personal data protection. We will notify you of any changes.

GDPR Privacy Policy MH300321

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