Monwell Limited (We or Monwell or the Company) is committed to protecting and respecting your privacy. This policy, together with our Terms & Conditions and any other documents referred to in it, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website, you are accepting and consenting to the practices described in this policy. This is the privacy statement for Monwell Limited (Monwell or We). Monwell Limited is a private company (company number 10350960) with its registered office at Greenhouse, 49 Green Lanes, London, England, N16 9BU. For the purpose of the Data Protection Act 1998 and the General Data Protection Regulation 16/679, the data controller is Monwell Limited, which has ICO registration number ZA210617.
The General Data Protection Regulation 16/679In this statement We have used certain terms which are set out in the EU’s General Data Protection Regulation (GDPR or the Regulation): personal data means: any information relating to an identified or identifiable natural person (data subject) an identifiable natural person is one who can be identified, directly or indirectly, 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 natural person <controller means: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data processor means: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller processing means: any operation or set of operations which is performed on personal data or on sets of 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
What is the lawful reason We use to process personal data?The four lawful reasons Monwell uses to process personal data are set out in Article 6 of the Regulation. Processing will only be lawful if and to the extent that at least one of the following applies:
- • the data subject has given consent to the processing of his or her personal data for one or more specific purposes (Article 6 (1) (a) (Consent);
- • processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Contract Performance);
- • processing is necessary for compliance with a legal obligation which We are subject to (Legal Obligations);
- • processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child (Article 6 (1) (f) (Legitimate Interest).
ConsentWhere We process personal data as a result of data subject consent, We ensure that consent is freely given, specific and informed, and established by a clear affirmative act. Where consent is withdrawn, we have set out (below) how this may be undertaken by the data subject.
Contract PerformanceWhere We enter into a contract with third parties, processing of personal data may, as a matter of course, be necessary in order to execute such contract or take pre-contract preparation steps.
Legal ObligationsWhere We have legal obligations which apply to Monwell, processing of personal data may be required by law.
Legitimate InterestWhere We process personal data as it is necessary for the purpose of our legitimate interests, We do so on the basis of a balanced evaluation of our interests and the rights and freedoms of the data subject which require protection. Presently, We have concluded that the way We manage the processing of personal data results in a cumulation of data subject protections which show that the balance is in favour of Monwell being able to rely on Article 6.1(f) of the Regulation as a lawful reason to process personal data. Your right to request that We stop processing personal data for our legitimate interests and withdrawal of your consent As required by the Regulation, consent should be as easy to withdraw, as it is to give. Data subjects may request that Monwell does not process your personal data, at any time. You may contact us to withdraw your consent using the contact details at the end of this privacy statement, using the following statement:
Withdrawal of consentI [STATE YOUR NAME] hereby withdraw my consent for Monwell Limited to process my personal data. Signed by data subject: [STATE YOUR NAME]
Our Status; How We use personal data
- • We may act a processor of personal data for our clients or subscribers, with whom we have signed a data processing agreement, which is compliant with the Regulation.
- • Monwell may act as a controller and where Monwell acts as a controller, any personal data We collect after profiling is treated and managed according to the approach We have set out above.
Why does Monwell need to collect and store personal data?We collect and store personal data to provide our clients and subscribers with the service they require as a purchaser or client, or, to improve our services; We do not process personal data for any reason other than this purpose. We only keep personal data for as long as is necessary in order to undertake this purpose. We are committed to ensuring that the information We collect and use is appropriate for this purpose, and does not constitute an invasion of the data subject’s right to privacy.
Will Monwell share my personal data with anyone else?Monwell will share information about your transactional behaviour and your marketing opt-in status with Guardian News and Media. Monwell may pass your personal data on to third-party service providers contracted to Monwell. In these circumstances, the third party may be another controller, processor or sub-processor. Where the third party is a processor or a sub-processor, they are obliged to keep your details securely, and to use them only to fulfil their contractual obligations to Monwell. When they no longer need your personal data to fulfil this service, they will dispose of the details in line with Monwell’s data retention policy. Where Monwell is required to send personal data outside of the European Economic Area, in some cases to jurisdictions which the EU has not deemed to be ‘adequate’ for the purposes of the Regulation, Monwell will ensure that such transfers are undertaken in a manner consistent with the requirements of the Regulation.
How will Monwell use the personal data it collects about me?Monwell will process personal data in a manner compatible with the Regulation. We will keep information accurate, up to date, and not keep it for longer than is necessary. Monwell is required to retain certain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will Monwell contact me?The personal data We process is subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure. We will get in touch with you where this is required under the Regulation.
Can I find out the personal data that the organisation holds about me?At your request and where this is technically possible, Monwell will confirm the information We hold about you and how it is processed. As set out in the Regulation you can request the following information:
- • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- • Contact details of the data protection officer, where applicable.
- • The purpose of the processing as well as the legal basis for processing.
- • If the processing is based on the legitimate interests of Monwell or a third party, information about those interests.
- • The categories of personal data collected, stored and processed.
- • Recipient(s) or categories of recipients that the data is/will be disclosed to.
- • If We intend to transfer the personal data to a third country or international organisation, information about how We ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, We will ensure there are specific measures in place to secure your information.
- • How long the data will be stored.
- • Details of your rights to correct, erase, restrict or object to such processing.
- • Information about your right to withdraw consent at any time.
- • How to lodge a complaint with the supervisory authority.
- • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as Well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- • The source of personal data if it wasn’t collected directly from you.
- • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.