A quick word on cookies
Privacy Notice – miggle Limited – Effective May 2018
The EU General Data Protection Regulation (GDPR), which is enforceable from 25 May 2018, provides new rights to individuals and requires organisations to provide information about their processing in a clear and transparent way. We have published this updated Privacy Notice to take into account new requirements and to explain how we collect, store and use personal data. When we refer to “we”, “us” or “our” in this Notice we mean miggle Limited.
miggle Limited is a specialist Internet consultancy, helping organisations get the most out of their investment in digital. Our company registration number is 6200250. Our VAT registration number is GB 909 8858 62.
This Privacy Notice applies to personal data collected by miggle Limited and processed at various locations across Sussex. miggle Limited, as a Data Controller, is committed to protecting the privacy of our clients and subscribers. We endeavour to comply with the Data Protection Act 1998, the EU General Data Protection Regulation (GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 (amended) and other relevant legislation.
How to contact us
If you have any questions about this Privacy Notice or would like to contact us about any other matter, please use the following contact information:
Email: [email protected]
How we collect your personal data
We collect personal data in the following ways:
- When you provide your contact details to us when requesting information about our products or services, either via the telephone, our online enquiry forms or face-to-face
- When you sign up for our miggle Limited email newsletter using our on-line form
- When you make an application for an open job position with miggle Limited via our on-line form or by direct email
- When you become a supplier of services to miggle Limited
- When you visit our website and allow Cookies
- Via openly available public sources (e.g. LinkedIn or company websites).
The types of personal data we collect
The personal data we routinely collect includes: Full name, Email address, Phone number, Job title, Company name. We do not collect any special categories of personal data, as defined under the GDPR. Our products and services are not aimed at children.
How we use your personal data
We may use your personal data for the following purposes:
|Purpose||Legal Basis for Processing|
|To fulfil a query, request for services and/or to administer our services||For the performance of a Contract or agreement|
|To provide information, or to contact you following your interaction with one of our on-line forms at miggle.one||Your Consent|
|To maintain records of job applicants||Your Consent|
|To maintain records of prospective, current and past clients and our suppliers||Our Legitimate Interests, which we have balanced with the interests of our clients, suppliers and business contacts|
|To contact you to ask if you are interested in our Services||Our Legitimate Interests, which we have balanced with the interests of our clients, suppliers and business contacts|
|To track your use of our websites and interaction with our newsletters. For example, to understand which newsletter content is most popular with our email audience. (Please also see our Cookie Notice below).||Our Legitimate Interests, which we have balanced with the interests of our clients, suppliers and business contacts|
|To send our email newsletter to you, if you are a current or past Client or Supplier.|
|To send email newsletters to you, if you have signed up using the online form at miggle.one.||Your Consent|
On the miggle website we invite you to opt-in and give your Consent to receive our newsletters. You can unsubscribe from these at any point by clicking on the unsubscribe link on any email you receive from us. Alternatively, you can unsubscribe by emailing [email protected]. We use a third-party provider, MailChimp, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see MailChimp’s privacy notice https://mailchimp.com/legal/privacy/.
The email newsletter is sent to only those who have opted-in through the opt-in procedure, and to those based on our legitimate interests in line with the Information Commissioner’s Office guidance on B2B marketing. Subscribers are at any time entitled to revoke the declaration of consent and anyone receiving the newsletter based on our legitimate interests has the right to opt-out at any time. Each email newsletter miggle Limited sends contains an unsubscribe link through which you may easily opt-out of receiving future email newsletters from us. If you do not wish to receive email newsletters from miggle Limited, simply click the unsubscribe link and follow the instructions to unsubscribe your e-mail address or to change your preferences.
Our business development team use direct marketing and prospecting e-mails Business to Business in-line with the Information Commissioner’s Office (ICO) guidance on B2B marketing. We adhere to the Privacy and Electronic Communications (EC Directive) Regulations 2003 (amended) and other relevant legislation. We will only ever directly contact businesses we believe we have a legitimate interest in making contact with; those who could benefit from using our Services, and we will always endeavour to contact the most relevant individual within those businesses.
An individual can object to our direct marketing and prospecting e-mails at any time by replying to an e-mail from miggle Limited with the word ‘Stop’ in the subject line. Once we receive this communication, we will cease contact immediately.
Your rights regarding your personal data
You have a number of rights under data protection law, which have been strengthened under the General Data Protection Regulation (GDPR):
Under certain circumstances, you have rights under data protection laws in relation to your Personal Information. You have the right to:
Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Information 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 Information. This enables you to ask us to delete or remove Personal Information 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 Information 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 Information 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 Information 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 Information 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 Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) 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; or
(d) 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 Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information 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 Information. 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.
If you wish to exercise any of the rights detailed above, please use the following contact details:
Email: [email protected]
Address: 100 Church Street, Brighton and Hove, BN1 1UJ
If you are concerned about the manner in which we have collected and used your personal data, please contact us using the contact details above – we will do our best to help. If you are unhappy with the way in which we have handled your personal data you have the right to contact the Information Commissioner’s Office.
Where we store your personal data
We store and process your personal data at dek based locations in the UK. We use cloud-based storage systems from Google and Microsoft, where data is not moved outside of the EEA. Where data is stored outside of the EEA in the USA, we ensure that service providers adhere to the EU-US and Swiss-US Privacy Shield frameworks and comply with the EU General Data Protection Regulation (GDPR).
How we keep your personal data secure
miggle take the protection of your personal data very seriously and we take appropriate steps to ensure your personal data is stored in a secure environment to prevent any unauthorised access. miggle may use external data service providers to process personal data on our behalf. When we do so we have appropriate agreements in place to protect the data. Any data transfers between external service providers and ourselves are conducted by secure means. Wherever possible, we do not transfer data outside of the EEA. Where data is stored outside of the EEA in the USA, we ensure that service providers adhere to the EU-US and Swiss-US Privacy Shield frameworks and comply with the EU General Data Protection Regulation (GDPR).
Sharing of your personal data
We will not share your personal information with any third parties for them to use for their own marketing purposes. We may disclose your personal data if required to do so by law.
How long we store your personal data for
We will only retain personal data for as long as is necessary for the purposes we are using it for. How long we retain data will vary depending on the purposes it is used for.
The website miggle.one
This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience.
Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive/device they should take necessary steps within their web browser security settings to disable/block all cookies from this website and its external serving vendors.
Other cookies may be stored to your computer/device hard drive by external vendors when this website uses referral programs, sponsored links or adverts such as Google AdWords. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected
We may also set cookies during your visit to our website to be used for remarketing purposes i.e. to show you miggle Limited products and services based on what you appear to be interested in. This means that you may see miggle Limited adverts and content on other websites. The cookies will enable us to monitor whether you see adverts, click on them and access our website as a result. To opt out of being tracked by Google Remarketing and all third party interest based advertising you can do so by visiting http://optout.networkadvertising.org/?c=1#!/.
Downloads & media files
Any downloadable documents, files or media made available on this website are provided to users at their own risk. While all precautions have been undertaken to ensure only genuine downloads are available users are advised to verify their authenticity using third party anti virus software or similar applications. We accept no responsibility for third party downloads and downloads provided by external third party websites and advise users to verify their authenticity using third party anti virus software or similar applications.
Contact & communication
Users contacting this website and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely, as detailed in the General Data Protection Regulation. Every effort has been made to ensure a safe and secure form to email submission process but advise users using such form to email processes that they do so at their own risk.
The website of miggle Limited contains information that enables a quick electronic contact to miggle Limited which also includes a general address of electronic mail (e-mail address). If you contact miggle Limited by e-mail or via the online contact form, the personal data transmitted by you the data subject is automatically stored. Your personal information is kept private and stored securely until a time it is no longer required or has no use.
Online contact form
We request information from you in our online contact form only so that we may answer you. To respond to your enquiry effectively we ask for your name, email address and other personal details that need to be supplied for the services or the advice you may require. Such personal data is transmitted on a voluntary basis by you to miggle Limited and stored for the purpose of contacting you. This personal data will never be sold to third parties and you may request that we delete this data at any time.
Although we only look to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text / banner / image links to other websites)
miggle Limited is not responsible for the privacy practices or the content of any third party websites. The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Customers and visitors who link to other third party websites from this website should check the privacy and security policy statements of such third party websites to understand the policies and practices of such third party websites as we are not responsible for those policies and practices. Customers and visitors who access a linked site may be disclosing their private information to the owner of such third party websites. It is your responsibility to keep such information private and confidential.
Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Social media platforms
Communication, engagement and actions taken through external social media platforms that this website participates on are subject to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate/engage upon them with due care and caution in regard to their own privacy and personal details. This website will never ask for personal or sensitive information through social media platforms and we encourage users wishing to discuss sensitive details to contact us by telephone or email.
This website uses social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
Social media widgets
Twitter: Twitter is a service of Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, UNITED STATES. If you live outside the United States, the data controller responsible for your information is Twitter International Company, an Irish company with its registered office at One Cumberland Place, Fenian Street, Dublin 2 D02 AX07 Ireland.
You may change your Twitter data privacy settings in your account settings here: http://twitter.com/account/settings.
Facebook: Facebook is a service of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, UNITED STATES.
If you wish to prevent the transfer to and storage of data by Facebook about you and your interaction with our website, you must first log out of Facebook before visiting the miggle Limited website. The data protection policies of Facebook provide additional information about the collection and use of data by Facebook, your rights in this regard, and the options available to you for protecting your privacy: https://www.facebook.com/about/privacy/. An overview of Facebook plugins is available here: https://developers.facebook.com/docs/plugins/.
LinkedIn: LinkedIn is a service of LinkedIn Corporation, LinkedIn Headquarters 2029 Stierlin Ct. Ste. 200 Mountain View, CA 9404, UNITED STATES.
There are tools freely available on the market that can be installed to block social media plug-ins with add-ons from being added to commonly used browsers. You use social sharing buttons at your own discretion and accept that doing so may publish content to your social media profile feed or page.
Shortened social media links
This website and its owners through their social media platform accounts may share web links to relevant web pages. Shortened URL’s; URL shortening is a technique used on the web to shorten URL’s (Uniform Resource Locators) to something substantially shorter. This technique is especially used in social media and looks similar to this example: https://bit.ly/2koCQUO. Users should take caution before clicking on shortened URL links and verify their authenticity before proceeding.
Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
miggle Limited has integrated the component of Google Analytics on this website via an additional software package called Google Tag Manager. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects data about the website from which a person has come (the referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimisation of a website and in order to carry out a cost-benefit analysis of various forms of incoming traffic, like clicks from Google, social networks and Internet advertising.
Google Analytics and Google Tag Manager are services and components of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data and information to evaluate the use of our website and to provide online reports, which show the activities on our website, and to provide other services concerning the use of our website for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyse the use of our website. With each call-up to one of the individual pages of this website, which is operated by miggle Limited and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject (you) will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google typically gains knowledge of personal information, such as the IP address of the data subject, which serves Google to understand the origin of visitors and clicks, and subsequently creates commission settlements. However, we ensure that the request which is sent to Google Analytics ensures that Google partially anonymise the IP address before it is written to disk, so that it can only be used to identify a general location rather than be used as a means to more accurately pin-point an individual user, or store an IP address, which might then be potentially used with other data to personally identify a data subject.
The cookie is used to store personal information, such as the access time, the general location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our website, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following link https://www.google.com/analytics/.
Updates to this notice
We review and update this Notice regularly to take account of changes to our processing and regulatory changes. We encourage you to review it from time to time. This Notice is effective from 24/05/2018 and was last updated on 31/08/2019 to reference our use of Google Tag Manager and Vimeo, as well as our new policy to anonymise IP addresses collected by Google Analytics.