Our Privacy Policy Your privacy is important to us. This privacy statement explains what personal data MCG Secure Ltd collects from you, through our interactions with you and how we use that data. MCG Secure Ltd utilises several electronic and manual systems to help operate the company and to provide you with the services we are contracted to provide. Personal Data That We Collect MCG Secure Ltd collects data to operate effectively and provide you the best possible service. You provide some of this data directly, such as when you ring our Sales Department to arrange quotations or our Service Department for support and you provide them with your name and contact information. We also get information when you contact us through our website. You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide a product or service, you may not be able to use that product or benefit from our service. The data we collect depends on the context of your interactions with MCG Secure Ltd, the choices you make including the products and features you use. The data we collect can include the following: • Name and contact data. We collect your first and last name, email address, postal address, phone number and other similar contact data. • Credentials. We collect passwords, password hints and similar security information used for authentication and system access. • Demographic data. We may collect data about you such as your, gender, country and preferred language. • Payment data. We collect data necessary to process your payment if you make purchases, such as your bank and credit card details. • Contacts. We may collect contact information such as name, address and telephone number of a personal contact, where that person is used to allow access to you premises for security purposes. • Content. We collect content of files and audio when necessary to provide you with contracted services. For example, we may hold floor plans of your building or we may retain an audio recording of a voice message left on our telephone system. How We Use Personal Data MCG Secure Ltd uses the data we collect for two basic purposes, described in more detail below: (1) to operate our business and provide (including improving and personalising) the products we offer, (2) to send communications, including promotional communications. Providing and improving our products. We use data to provide and improve the systems we offer and perform essential business operations. This includes operating the systems, maintaining and the performance of the systems and providing customer support. Examples of such uses include the following: • Providing the Systems - We use data to carry out your transactions with us and to provide our systems to you. • Customer support. We use data to diagnose product problems, repair customers' devices and provide other customer care and support services. • Security, Safety and Dispute Resolution - We use data to protect the security and safety of our products and our customers, to detect and prevent fraud, to resolve disputes and enforce our agreements. • Business Operations - We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions and report on the performance of our business. • Communications - We use data that we collect to communicate with you and personalise our communications with you. For example, we may contact you by phone or email or other means to inform you when a contract is ending, let you know when security updates are available, update you or enquire about a service or repair request. Additionally, we may give you the option to sign up for email subscriptions and choose whether you wish to receive promotional communications from MCG Secure Ltd email, SMS, post and telephone. For information about managing your contact data, email subscriptions and promotional communications, please visit the Access and Controls section of this privacy statement. Reasons We Share Personal Data We only share your personal data with your consent or as necessary to complete any transaction or provide any system or service you have requested or authorised. For example, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction. In addition, we also share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we've hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets. Finally, we will access, transfer, disclose and preserve personal data, including your content (such as the content of your emails, or files in private folders on OneDrive), when we have a good faith belief that doing so is necessary to: • Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies; • Protect our customers, for example to prevent spam or attempts to defraud users of our products, or to help prevent the loss of life or serious injury of anyone; • Operate and maintain the security of our systems, including to prevent or stop an attack on our computer systems or networks; or • Protect the rights or property of MCG Secure Ltd, including enforcing the terms governing the use of the services. How To Access & Control Your Personal Data You can view, edit or delete your personal data by contacting MCG Secure Ltd by phone, post or email and completing our Subject Access Request Form. We will respond to requests to access or delete your personal data within 30 days. Your Communications Preferences You can choose whether you wish to receive promotional communications from MCG Secure Ltd by email, postal mail and telephone. If you receive promotional email from us and would like to opt out, you can do so by following the directions in those messages. You can also make choices about the receipt of promotional email, telephone calls and post by contacting MCG Secure Ltd and update contact information, manage contact preferences, and opt out of email subscriptions. These choices do not apply to mandatory service communications that are part of certain MCG Secure Ltd services. Browser-Based Controls Cookie Controls. Relevant browser-based cookie controls are described in the Cookies section of this privacy statement. MCG Secure Ltd uses cookies (small text files placed on your device) to provide our website and online services and to help collect data. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your computer. Our Use of Cookies The MCG Secure Ltd website uses cookies for several purposes, including: • Storing your Preferences and Settings. Settings that enable the website to operate correctly or that maintain your preferences over time may be stored on your device. such as language, browser and multimedia player settings, so those do not have to be reset each time you return to the site; • Security. We use cookies to detect fraud and abuse of our websites and services; • Collecting data from Google, Twitter and Facebook, to better improve the user experience of our website. How to Control Cookies Most web browsers automatically accept cookies but provide controls that allow you to block or delete them. For example, in Microsoft Edge, you can block or delete cookies by clicking Settings > Privacy > Cookies. Instructions for blocking or deleting cookies in other browsers may be available in each browser's privacy or help documentation. Notice To End Users If you use an email address provided by an organisation you are affiliated with, such as an employer or school, to access MCG Secure Ltd products or services, the owner of the domain (e.g. your employer) associated with your email address may access and process your data, including the contents of your communications and files. Other Important Information MCG Secure Ltd adheres to applicable data protection laws in the European Economic Area, which if applicable includes the following rights: • If the processing of personal data is based on your consent, you have a right to withdraw consent at any time for future processing; • You have a right to request from us, a “data controller” as defined in the law, access to and rectification of your personal data; • You have a right to object to the processing of your personal data; and • You have a right to lodge a complaint with a data protection authority. When we process personal data about you, we do so with your consent and/or as necessary to provide the system and services that you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests of MCG Secure Ltd as described in the “How We Use Personal Data” and “Reasons We Share Personal Data” sections above. When we transfer personal data from the European Economic Area, we do so based on a variety of legal mechanisms, as described in “Where We Store and Process Personal Data” below. Security Of Personal Data MCG Secure Ltd is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit highly confidential data (such as a credit card number or password) over the Internet, we protect it through the use of encryption. Where We Store & Process Personal Data Personal data collected by MCG Secure Ltd is stored, processed and backed up either within the European Economic Area (EEA) or in an adequate country as defined within GDPR, often with a backup to a data centre in another region. We transfer personal data from the European Economic Area and Switzerland to other countries, which have been determined by the European Commission to have an adequate level of data protection. Our Retention Of Personal Data MCG Secure Ltd retains personal data for as long as necessary to provide our systems and services and fulfil the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly. The criteria used to determine the retention periods includes: • How long the personal data is needed to provide the products and operate our business. This includes such things as maintaining those systems, keeping our systems secure and maintaining appropriate business and financial records. This is the general rule that establishes the baseline for most data retention periods. • If the personal data is sensitive. If so, a shortened retention time would generally be appropriate. • If you have provided consent for a longer retention period. If so, we will retain data in accordance with your consent. • If MCG Secure Ltd is subject to a legal, contractual or similar obligation to retain the data. Changes To This Privacy Statement We will update this privacy statement when necessary to reflect customer feedback and any changes in our products or services which may materially affect it. When we post changes to this statement, we will revise the "last updated" date at the top of the statement and outline the changes made. If there are material changes to the statement or in how MCG Secure Ltd will use your personal data, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this privacy statement to learn how MCG Secure Ltd is protecting your information. How To Contact Us If you have a privacy concern, complaint or a question concern any aspect of this notice please contact our Data Protection Manager either by email (info@mcgsecure.co.uk), phone (+44 (0) 028 92 449599) or by post (MCG Secure Ltd, Unit 36, 6 Enterprise Crescent, Lisburn, Antrim, BT28 2BP, UK). We will respond to questions or concerns within 30 days.