Mosaic Smart Data Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and who we share it with when you register to receive our detailed analytical data. This privacy notice also tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Mosaic Smart Data Limited collects and processes your personal data, including any data you may provide through our website when you register for detailed analytical data.
Our analytical data is not intended for consumers and is purely for business; we do not knowingly collect data relating to consumers (save for employee information of companies and corporate bodies).
It is important that you read this privacy notice together with any other privacy or fair processing notices and policies we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and policies and is not intended to override them.
Mosaic Smart Data Limited is a controller and responsible for your personal data (also collectively referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy officer using the details set out below.
If you have any questions about this privacy notice, please contact our data privacy officer in the following ways:
Email address: firstname.lastname@example.org
Postal address: 25 Finsbury Circus, London, EC2M 7EE, United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notices under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website will include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notices of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
If you register for detailed analytical data, we will collect, use, store and transfer the following kinds of personal data about you which we have grouped together as follows:
- Identity Data: your first name and last name, your username or similar identifier (if we provide you with one), your title, your employer (i.e. the corporate subscriber that will use our detailed analytical data), your position (job description) and (if identifiable) your gender.
- Contact Data: your corporate email address and telephone number(s).
- Technical Data: your internet protocol (IP) address, your login data, your browser type and version, your time zone setting and location, your browser plug-in types and versions, your operating system and platform, and your other technology on the devices you use to access this website.
- Usage Data: information about how you use our website and our analytical data.
- Profile Data:your username and password and, possibly, your feedback and survey responses if we produce these.
- Marketing and Communications Data: if you subsequently opt-out, your preference in opting out of receiving marketing from us and our third parties and your communication preference.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We collect data from and about you solely through:
- Direct interactions. You will give us your Identity Data, Contact Data, Profile Data and Marketing and Communications Data by registering your company for detailed analytical data, responding to feedback and surveys and opting-opt from direct marketing. You may also give us such data by corresponding with us by post, phone, email or otherwise.
4. HOW YOUR PERSONAL DATA IS USED
Your personal data is only used when the law allows us to. Most commonly, your personal data will be used in the following circumstances:
- Where we provide you with our detailed analytical data.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we (or third paiites) need to comply with a legal obligation.
The lawful basis section below explains more about the types of lawful basis for the processing of personal data.
Purposes for which your personal data is used
We have set out below, in a table format, a description of all the ways in which we and our third party business partners plan to use your personal data, and which of the legal bases we and they rely on to do so. We have also identified what our and their legitimate interests are where appropriate.
Note that we and they may process your personal data for more than one lawful ground depending on the specific purpose for which we or they are using your data. Please feel free to contact us if you need details about the specific legal ground we and they will be relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you to receive detailed analytical data||(a) Identity Data|
(b) Contact Data
|To deliver our detailed analytical data||(a) Identity Data|
(b) Contact Data
(c) Profile Data
|To manage our relationship with you which will include:|
(a) notifying you about changes to our terms or privacy notices
(b) Asking you to leave a review or take a survey
|(a) Identity Data|
(b) Contact Data
(c) Profile Data
(d) Marketing and Communications Data
|(a) Necessary to comply with a legal obligation|
(b) Necessary for our legitimate interests and those of third parties (to keep our records updated and to study how subscribers use our and others’ products/services, to develop them and grow our or their business and our supplier relationships)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity Data|
(b) Contact Data
(c) Technical Data
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
(b) Necessary to comply with a legal obligation
|To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity Data|
(b) Contact Data
(c) Profile Data
(d) Marketing and Communications Data
(f) Technical Data
|Necessary for our legitimate interests and those of third parties (to study how subscribers use our and others’ products/services, to develop them, to grow our or their business and supplier relationships and to inform our marketing strategy)|
|To use data analytics to improve our website, our and third party products/services, marketing, relationships and experiences||(a) Technical Data|
(b) Usage Data
|Necessary for our legitimate interests and those of third parties (to keep our website and products/services updated and relevant, to develop our or their business and our supplier relationships and to inform our marketing strategy)|
|To make suggestions and recommendations to you about our and others’ goods and services that may be of interest to you||(a) Identity Data|
(b) Contact Data
(c) Technical Data
(d) Usage Data
(e) Profile Data
(f) Marketing and Communications Data
|Necessary for our legitimate interests and those of third parties (to develop our or their products/services and grow our or their business and our supplier relationships)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us and third parties
We and our third party business partners may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we or they think you may want or need, or what may be of interest to you. This is how we and they decide which products, services and offers may be relevant for you (marketing).
You will receive marketing communications from us and from our selected third party suppliers (see third-party marketing) until you opt out of receiving that marketing.
Our detailed analytical data is developed in part from data supplied by CLS Services Ltd. and Mitsubishi UFG Financial Group.
We will share your personal data with CLS Services Ltd. and Mitsubishi UFG Financial Group who may (or their affiliates may) market their own products and services to you for their legitimate interests. They will also be a controller and be responsible for your personal data.
You can ask us or our third party business partners to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any other product/service or transaction with us.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. CLS Services Ltd. and Mitsubishi UFG Financial Group will do the same.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. CLS Services Ltd. and Mitsubishi UFG Financial Group will do the same and they may have their own privacy notices in this regard (which we encourage you to read).
Please note that we, CLS Services Ltd. and Mitsubishi UFG Financial Group may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We will share your personal data with CLS Services Ltd. and Mitsubishi UFG Financial Group as set out above (see third-party marketing) and, in addition, the parties set out below for the purposes for which your personal data is used above.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
CLS Services Ltd. and Mitsubishi UFG Financial Group will use your personal data for their own purposes, both for the purposes for which your personal data is used above and potentially for new purposes too as explained above at change of purpose. We do not, however, allow our External Third Parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Your data may be transferred outside the European Economic Area (EEA).
Whenever your personal data is transferred out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Your personal data will only be transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Specific contracts may be used which give personal data the same protection it has in Europe.
- Your data can be transferred to US entities if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
CLS Services Ltd. and Mitsubishi UFG Financial Group are obliged to do the same by law.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. CLS Services Ltd. and Mitsubishi UFG Financial Group will have their own retention periods for your personal data which you can request from them directly.
In some circumstances you can ask us and each of CLS Services Ltd. and Mitsubishi UFG Financial Group to delete your data: see your legal rights below for further information.
In some circumstances we will 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. CLS Services Ltd. and Mitsubishi UFG Financial Group may do the same.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us. CLS Services Ltd. and Mitsubishi UFG Financial Group should be contacted directly in respect of their use of your data.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Consent means your agreement which must be freely given, specific, informed and be an unambiguous indication of your wishes by which they, by a statement or by a clear positive action, signify agreement to the processing of your personal data. You do this when registering for our detailed analytical data. Consent can be withdrawn at any time but please note that the withdrawal of consent to receive our detailed analytical data will not prevent us using your personal data for legitimate interests (see purposes for which your personal data is used above) although you can always opt-out from certain processing as explained above and you have your legal rights below too.
Legitimate Interest means the interest of our business or those of a third party in conducting and managing business to develop and give you the best services/products. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before processing your personal data for legitimate interests and our third party business partners are obliged to do the same by law. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law) and our third party business partners are obliged to do the same by law.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties
- Service providers acting as processors who provide IT and system administration services (e.g. AWS, Google, Microsoft).
- Professional advisers, acting as processors or joint controllers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.