Privacy Notice

The Meee Partnership Limited takes your privacy very seriously. Please read this Privacy Policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and the Data Protection Act 2018 and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

This Privacy Policy sets out the procedures that are to be followed when dealing with personal information. The procedures and principles set out herein must be followed at all times by us, our employees, agents, contractors, or other parties working on behalf of us.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	The Meee Partnership Limited
Our data privacy manager	Paula Harding paula@meee.global
Personal information	Any information relating to an identified or identifiable individual
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
Accurate and kept up to date
Kept in a form that identifies you for only as long as necessary for the purposes we have told you about
Kept securely

What types of personal information do we collect about you

We may collect and use the following personal information about you:

when you make a booking or an online enquiry with us we may ask for your name, gender and contact information, including e-mail address, telephone number and company details
if you attend one of our workshops we may ask for your name, gender and contact details including email address and telephone number, date of birth and national insurance number
If you register an account with us we will ask for your name, gender and contact details including email address and telephone number, date of birth and national insurance number, employment and education status, your local job centre and your interests
location data, if you choose to give this to us
your personal or professional interests and preferences
your professional online presence, eg LinkedIn profile
information from accounts you link to us, eg Facebook
your transaction/payment information when you make an online purchase with us (but please note that full debit card and credit card information is not processed by us as it is passed through to a PCI-DSS compliant third party payment provider in accordance with good industry standard)
your image, where it is captured by CCTV or other visual recording equipment on our owned or occupied sites
if you contact us online, we may keep a record of your email correspondence
if you contact us by telephone, we may record and/or monitor telephone conversations for training and customer services reasons
if you enter a competition or complete a survey we will collect your name and relevant contact information
if you report a problem with our products and services we will collect your name and relevant contact information
if you make a complaint in connection with our products and services we will collect your name and relevant contact information

Personal information we collect and/or observe about you

Based on how you have used our products and services in the past and your activity on our website and by telephone, we collect the following personal information from you:

details of the products and services we have provided to you in the past
details of your visits to our website, and of the resources that you access. We may use visitor information to measure the entry and exit points of visitors to the website and respective numbers of visitors to various pages and sections of the website and details of searches performed. We may also use this information in the future to measure the usage of advertising banners, and other "click throughs" to and from the website. We have security processes in place to ensure that your personal information is held on a central database and is not accessible by any unauthorised persons. However, persons such as IT systems suppliers may need to have access to the system from time to time
details of the website(s) you visited before you use a link to our website, pages visited in our website, and time spent on each. Information about your computer, or mobile device. This is statistical data about our users’ browsing actions

Personal information we collect and use for legal, compliance, regulatory and crime detection and prevention purposes

We process your personal information so that we can meet our legal, compliance and regulatory obligations, for legal purposes, such as to respond to a valid legal claim, summons or regulatory order.

We also process your personal information for crime prevention and detection purposes.

The personal information is required to provide products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and services to you.

Children Under Thirteen

Our products and services include working with children under 13 years old. We obtain parental, guardian or teacher consent to the processing for children in this category, and make reasonable efforts to verify that the person providing consent holds parental responsibility or the equivalent for the child.

How your personal information is collected

We collect most of this personal information directly from you-in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:

from another person making a booking or enquiry on your behalf
from you when you create an account on our website
from you when you request marketing or information about our products and services to be sent to you
from you when you give us feedback or provide a testimonial
from you when you subscribe to our newsletter
from our promotion partners
from social media
from a third party with your consent
from publicly accessible sources, eg Companies House
from cookies on our website-for more information on our use of cookies, please see our cookies policy
via our IT systems, eg
- door entry systems and reception logs;
- automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email systems

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:

to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party; or
where you have given consent

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us 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 tables below.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products and services to you	For the performance of our contract with you or to take steps at your request before entering into a contract. For example, to manage your booking and to take payment for your booking or online purchase
To register with us and/or register an account on our website	For our legitimate interests to provide products and services to you
To manage our relationship with you which will include: (a) notifying you about changes to our terms of Privacy Policy; or (b) asking you to leave a review or take a survey	To comply with our legal and regulatory obligations For our legitimate interests (to keep our records updated and to study how you use our products and services) On the basis of your explicit consent
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	For our legitimate interests (to study how you use our services, to develop them, to grow our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	For our legitimate interests (to develop our services and grow our business)
To enable you to partake in a prize draw, competition or complete a survey	For our legitimate interests (to study how you use our services, to develop them and grow our business) For the performance of our contract with you On the basis of your explicit consent For the performance of our contract with you
To prevent and detect fraud against you	For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Improve our products and services	For our legitimate interests
Ensuring business policies are adhered to, eg policies covering security and internet use	For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings	For our legitimate interests; with your consent, ie to promote our business to existing and former customers
To publish customer testimonials on our website, social media sites and in publications we issue	For our legitimate interests; with your consent, ie to help promote and build our business
For debt collection and credit vetting to project our business against financial loss	For our legitimate interests or those of a third party, ie to ensure our customers are likely to be able to pay for our products and services
To seek to protect and promote your health and safety and that of our other customers, staff and third parties	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party
To seek to detect, investigate, prevent and report crime and anti-social behaviour	For our legitimate interests or those of a third party, ie to detect and prevent crime and anti-social behaviour
For resolving complaints dealing with disputes and legal proceedings	To comply with our legal and regulatory obligations

Promotional communications

If you have made an enquiry or purchase on our website or by telephone, your personal information may be used by us in the ways the law allows, to contact you by post or electronic means (email or text message) about our services, including exclusive offers, promotions or new services. We will only do this if you did not opt out of such marketing at the point where we collect your contact details.

If you have not made an enquiry or purchase, we will only send you information and offers by email or text message if you sign up (opt in) to receive such marketing.

We will always treat your personal information with the utmost respect and never sell or share it with other organisations outside the Meee Partnership’s group for marketing purposes.

We will update you with occasional offers and information that we think will be of interest to you, using legitimate interest as a legal basis.

What you need to do if you don’t want to receive our promotional communications

You have the right to opt out of receiving promotional communications at any time by:

contacting us by email to info@meee.global
contacting us by writing to us at The Meee Partnership Limited, 16 Trinity Square, Llandudno, North Wales, LL30 2RB
using the ‘unsubscribe’ link in emails

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal information with

We routinely share personal information with:

companies within the Meee Partnership group
our suppliers, sub-contractors, business partners who help us to provide our services to you
the Department for Work and Pensions
third parties we use to help deliver our services to you, eg payment service providers
other third parties we use to help us run our business, eg marketing agencies or website hosts
third parties approved by you, eg social media sites you choose to link your account to or third party payment providers
credit reference agencies
our insurers and brokers
our bank
our card payment facilitators, that help us process customer payments and assist us in detecting and preventing fraudulent payments or bookings

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We may also share personal information with external auditors, eg in relation to the audit of our accounts.

We may disclose and exchange information with law enforcement agencies, regulatory bodies and external law firms (acting on your instructions) to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

Where your personal information is held

Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.

How long your personal information will be kept

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, contractual and/or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your personal information: See ‘your rights in relation to any personal information we hold about you’ 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.

Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Transferring your personal information out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), eg:

service providers located outside the EEA
if you are based outside the EEA

These transfers are subject to special rules under European and UK data protection law.

These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.

If you would like further information please contact our data privacy manager (see ‘How to contact us’ below).

Your rights in relation to any personal information we hold about you

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal information (the right of access) We may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. That may include information about your previous booking(s) or other purchases. If someone is acting on your behalf they will need to provide written and signed confirmation from you that you have given your authority to that person/company for them to make the request. We may not provide you with a copy of your personal information if it includes the personal information of other individuals or we have another lawful reason to withhold that information
Rectification	The right to require us to correct any mistakes in your personal information
Withdrawing your consent	Where we rely on your consent as the legal basis for processing your personal information, as set out in section above titled ‘How and why we use your personal information’, you may withdraw your consent at any time. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, please see the section titled ‘What you need to do if you don’t want to receive our promotional communications’ for further details. If you would like to withdraw your consent to us processing any special categories of personal information, please contact our data privacy manager. Please note if you ask us to stop processing this information, it may mean we won’t be able to provide all or parts of the products and services you have requested. If we have to cancel your booking or other purchase as a result, you may incur a cancellation charge If you withdraw your consent, our use of your personal information before you withdraw is still lawful
To be forgotten	The right to require us to delete your personal information In certain situations, you may ask for your personal information to be removed from our systems by e-mailing or writing to us at the address at the end of this Privacy Policy. Provided we do not have any continuing lawful reason to continue processing or holding your personal information, we will make reasonable efforts to comply with your request
Restriction of processing	The right to require us to restrict processing of your personal information-in certain circumstances, eg if you contest the accuracy of the personal information We may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings
Data portability	Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out in section titled ‘How and why we use your personal information’, you have the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that personal information to a third party You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if it contains the personal information of other individuals or we have another lawful reason to withhold that information
To object	The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests
Not to be subject to automated individual decision-making	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

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

email, call or write to our data privacy manager-see below: ‘How to contact us’
let us have enough information to identify you
let us have proof of your identity and address; and
let us know what right you want to exercise and the information to which your request relates

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that our Data Privacy Manager can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on 5th July 2018 and last updated on 5th July 2018.

We may change this privacy notice from time to time-when we do we will inform you via our website.

How to contact us

Please contact our data privacy manager by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details	Our data privacy manager’s contact details
The Meee Partnership Limited 16 Trinity Square, Llandudno, North Wales, LL30 2RB Tel: 0333 567 9009	Paula Harding 16 Trinity Square, Llandudno, North Wales, LL30 2RB Email: paula@meee.global Tel: 0333 567 9009

Do you need extra help?

If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).