Privacy Policy

Because of the international nature of our business, we transfer Personal Data within the MSI group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Policy. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. You are entitled to request a copy of our Standard Contractual Clauses using the contact details provided in Section (R) below.

Please note that when you transfer any Personal Data directly to a MSI entity established outside the EEA, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Policy.

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

We take every reasonable step to ensure that:

• your Personal Data that we Process are accurate and, where necessary, kept up to date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data are as follows:

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

• permanently delete or destroy the relevant Personal Data; or
• anonymize the relevant Personal Data.

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

• the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, Apps, Products, or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
• the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
• the right to request rectification of any inaccuracies in your Relevant Personal Data;
• the right to request, on legitimate grounds:
• erasure of your Relevant Personal Data; or
• restriction of Processing of your Relevant Personal Data;
• the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
• where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive Policy of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
• the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (R) below. Please note that:

• in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

When you visit a Site or use an App we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We Process Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy .

All use of our Sites, Apps, Products, or services is subject to our Terms of Use . We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, Apps, Products, or services that may be of interest to you. If we provide Sites, Apps, Products, or services to you, we may send information to you regarding our Sites, Apps, Products, or services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Apps, Products, or services you have requested.

For the purposes of this Policy, the relevant Controllers are:

Our Data Protection Officer is contactable using the details set out above.

Personal Data: To manage your personal data, please refer here.

• "App"means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).
• "Adequate Jurisdiction" means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
• "Cookie" means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
• "Controller"means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
• "Data Protection Authority" means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
• "EEA" means the European Economic Area.
• "Personal Data" means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
• "Process", "Processing" or "Processed" means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• "Processor"means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
• "Profiling" means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
• "Relevant Personal Data" means Personal Data in respect of which we are the Controller.
• "Sensitive Personal Data" means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.
• "Standard Contractual Clauses" means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
• "Site"means any website operated, or maintained, by us or on our behalf.