PRIVACY AND COOKIES POLICY
Effective Date: 6th August 2013
1. Who are we?
1.1 We are Momenta Holdings (PPI) Limited.We own and operate this site. Our contact details are on the site. Please contact us if you have any questions or feedback about this policy.
1.2 We are registered with the Information Commissioner’s Register of Data Controllers under number Z8833257.
2. What’s the point of this policy?
2.1 This policy tells you how we deal with your “personal data” (i.e. technical term for information about any identified or identifiable living person). Please read on to find out what kinds of personal data we collect, how we use and protect it, to whom we disclose it and how you can access and rectify it.
2.2 Please do not use our site unless you are completely happy with this policy. If you do use our site, we will assume that you do accept it.
3. Might the policy change?
3.1 It may well do and so you should check it whenever you visit our site. We will assume you agree to the revised policy if you use the site after the effective date shown at the top of the policy.
4. What personal or other data do we collect?
4.1 We collect and store the information which you give us via forms on our site - such as your contact details and information and documents supplied or uploaded by applicants or associates - or when communicating with us by email or in some other way. The information may include sensitive personal data such as details of criminal convictions.
4.2 We may receive and store certain information automatically when you interact with us. Examples include the internet protocol (IP) address used to connect your computer to the internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, login details, the full URL clickstream to, through and from our site (including date and time), cookie number, activity on our website including the pages you visited and searches you made.
4.3 If you are an associate applicant, we may collect supplemental information about you from third parties including a credit check, employment, academic and other references, fraud database checks and a Basic Criminal Disclosure check, which constitutes sensitive personal data.
5. What about cookies?
5.2 Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the site owner or others. Session cookies are temporary cookies that remain in the cookie file of your browser only until you leave the site. They allow websites to link your actions during a browser session. Persistent cookies stay in the cookie file of your browser for longer (though how long will depend on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them, visit: www.allaboutcookies.org.
5.3 Cookies are used on this site for the following purposes:
a) Associate Portal: This cookie, which is used on our associated portal, allows you to proceed through many pages of the site quickly and easily without having to authenticate or reprocess each new area you visit. If you disallow or delete this cookie, then you will not be able to access any features that require authentication. Whether this cookie is persistent or not depends whether or not you tick “remember me” checkbox. If you do, the cookie will persist for 90 days.
c) civicAllowCookies: This cookie takes note of whether you are happy to accept cookies on this website based on your response to the message which appeared when you first visited the site. This persistent cookie will remember your preference for up to 60 days.
5.4 By continuing to use our site, having seen our cookie notice, we assume that you consent to use of the cookies outlined above.
6. How do we use your personal data?
6.1 We use your personal data to enable us to process associate applications and supply our services.
6.2 We use your personal data to help us communicate with you effectively should you try to contact us via our site including verification of any claims you may make.
6.3 We may use personal data to recognize you when you visit or return to our site to track anonymised traffic and usage patterns, to prevent or detect fraud or abuses or to help us improve our site.
6.4 We retain personal data in order to comply with legal obligations, enforce our terms and conditions, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations and take other actions as permitted by law.
6.5 We may access, remove, alter, store or otherwise use any personal data if we have reason to believe that it breaches our terms and conditions, or that such steps are necessary to protect us or others, or that a criminal act has been committed, or if we are required to do so by law or appropriate authority.
7. How do we protect personal data?
7.1 Security is a high priority. We take appropriate precautions to protect personal data from loss, misuse, unauthorised access or disclosure, alteration or destruction using the same safeguards as we use for our own proprietary information.
7.2 Email and other electronic communications are not secure if they have not been encrypted. Your communications may pass through servers in a number of countries before they reach us. So we do not accept responsibility for any unauthorised access to or loss of personal data that stems from a cause beyond our control. Nor can we be held responsible for the actions or omissions of other users or third parties who may misuse your personal data which they collect from the site.
8. To whom do we disclose personal data?
8.1 We may allow access to your personal data by third parties who supply us with a service - for the purpose of their service only and in accordance with our instructions. Examples include website hosts and businesses which assist us in undertaking communications or monitoring our site or carrying out references checks with third parties as explained above.
8.2 We may pass your personal details to third parties from whom we request references or other information about you.
8.3 Should any potential fraud or other criminal offence by you come to our attention, we reserve the right to record the details of this on the relevant fraud prevention database. This information may be accessed from the UK and other countries and used by law enforcement agencies and by us and other organisations to prevent fraud.
8.4 We may transfer your personal data to our other group companies, clients or agents who may be located outside the European Economic Area.
8.5 We may disclose personal data so far as reasonably necessary:
a) if we have reason to believe that it breaches our terms and conditions, or that such steps are necessary to protect us or others, or that a criminal act has been committed, or if we are required to do so by law or appropriate authority; or
b) in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.
9. How can you access and rectify personal data?
9.1 You can access and rectify your personal data by contacting us by the means shown on our website. We may charge an administration fee in line with data protection laws.
9.2 For information about your rights under UK data protection laws, see the website of the UK Information Commissioner.