This Privacy Policy was last updated on May 24, 2018

Merlin Scott Associates Limited ("MSAL") operates https://www.merlinscottassociates.co.uk, https://www.industry-averages.co.uk and may operate other websites. It is MSAL's policy to respect your privacy regarding any information we may collect while operating our websites. MSAL has a legitimate interest in collecting and processing the information of customers and potential customers and has performed a Legitimate Interests Assessment to comply with the GPDR as detailed below.

This Privacy Policy explains what information of yours will be collected by us when you access the Services, how the information will be used, and how you can control the collection, correction and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Policy. The use of information collected through our sites shall be limited to the purposes under this privacy policy.

By becoming a customer, logging in or using the features of our sites you are accepting and consenting to the practices described in this policy. Please note that this includes consenting to the processing of any personal information you provide, as described below.

Please review this Privacy Policy carefully. By using our Services, you consent to the use and sharing of your personal information as described in this Privacy Policy.

IF YOU DO NOT AGREE WITH THESE PRACTICES, PLEASE DO NOT USE THE SERVICES, OR OTHERWISE PROVIDE US WITH YOUR PERSONAL INFORMATION.

We may amend this privacy policy at any time. Any changes we may make will be posted on this page, so please check back frequently. Your continued use of our website(s) after posting will constitute your acceptance of, and agreement to, any changes.

For the purpose of the Data Protection Act 1998 (the Act) and the European Parliament and the Council's Regulation 2016/679 of 27 April 2016 ("GDPR"); the Data Controller is Merlin Scott Associates Limited, Dunselma Castle, Strone, Dunoon Argyll, United Kingdom, PA23 8RU. Company number: 02810804.

We may collect and process the following information about you:

Depending on how you use the Services, you may be required to provide certain personally identifiable information ("personal information"), which may include, but is not limited to the following:

• First name
• Surname
• Position
• Company name
• Email address
• Contact telephone
• Company Address
• Industry you belong to

If you purchase a report payment will be processed by one of our third party providers or by direct transfer from your bank. Your credit or debit card details are not held by us.

Like most website operators, MSAL collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. MSAL's purpose in collecting non-personally identifying information is to better understand how MSAL's visitors use its website.

Gathering of Personally-Identifying Information

Certain visitors to MSAL's websites choose to interact with MSAL in ways that require MSAL to gather personally-identifying information. The amount and type of information that MSAL gathers depends on the nature of the interaction. For example, we ask customers or potential customers on https://www.merlinscottassociates.co.uk to provide some or all the details above. Those who engage in transactions with MSAL are asked to provide additional information, including as necessary the personal and financial information required to process those transactions. In each case, MSAL collects such information only insofar as is necessary or appropriate to fulfil the purpose of the visitor's interaction with MSAL. MSAL does not disclose personally-identifying information other than as described below. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain website-related activities.

Storage and transfer of personal information

Your personal information and files are stored on our servers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information by using https protocols, we cannot guarantee the security of your information transmitted to our sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Cookies

Cookies are bits of electronic information that a website may transfer to a visitor's computer to identify specific information about the visitor's visits to a website. The MSAL websites use a browser feature known as a cookie, which assigns a unique identification to your computer. In case you do not wish us to collect such information kindly refer to our cookie policy to understand how to disable cookies for your browser. However, please note that if you disable the use of cookies on your computer, some functionality of our site will not work.

Use of Information

We primarily use the information including but not limited to following purposes:

• To facilitate your usage of our services;
• To process or facilitate payments for Services;
• To contact you with promotional offerings or other communications that may be of interest to you;
• To contact you in connection with your Services;
• To perform internal operations necessary to provide our Services, troubleshooting software bugs and operational problems, to conduct data analysis, testing, research, and to monitor and analyse usage and activity trends;
• To personalise the content and features you see when you visit our sites;
• To respond to your questions and assist with problems with our Services;
• To enhance other information, we have about you to help us better understand you and determine your interests;
• To assist you when you contact our customer support services, including a) Direct your questions to the appropriate customer support person, b) Investigate and address your concerns, c) Monitor and improve our customer support responses;
• For service development. This allows us to improve and enhance the safety and security of our services and develop new features;

We may use your information for any other purpose disclosed to you at the time we collect or receive the information, or otherwise with your consent.

Sharing of information

MSAL discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors and affiliated organisations that (i) need to know that information in order to process it on MSAL's behalf or to provide services available at MSAL's websites, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organisations may be located outside of your home country; by using MSAL's websites, you consent to the transfer of such information to them. MSAL will not rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors and affiliated organisations, as described above, MSAL discloses potentially personally-identifying and personally-identifying information only in response to a court order or other governmental request, or when MSAL believes in good faith that disclosure is reasonably necessary to protect the property or rights of MSAL, third parties or the public at large. If you are a registered user of an MSAL website and have supplied your email address, MSAL may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what's going on with MSAL and our products. If you send us a request (for example via email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. MSAL takes all measures reasonably necessary to protect against the unauthorised access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.

Business Transfers

If MSAL, or substantially all of its assets, were acquired, or in the unlikely event that MSAL goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of MSAL may continue to use your personal information as set forth in this policy.

Testimonials

We display personal testimonials of customers on our Sites. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us using the current contact details shown on our website.

Data Retention

We retain your information while your account remains active, unless you request deletion of your information or account. In some cases, we may retain certain information about you as required by law or other purposes even if you delete your account with us.

Security

Your personal information is extremely important to us. Your information resides on a secure server that only selected personnel have access to. In addition to our precautions, it is important that you do not share your password with anyone. Although we try our best to protect your information, we cannot completely eliminate security risks associated with Personal Information.

Your Rights

Right to be informed: You are entitled to know whether we hold your personal information and the purpose your personal data is processed for. You can request this data at any time using the current contact details shown on our website.

Right of access: You are entitled to obtain a copy of your personal data, together with an explanation of the categories of data being processed and the purposes of such processing. You can request this information at any time using the current contact details shown on our website.

Right to rectification: You are entitled to correct/update your personal information held us. You can request this data at any time using the current contact details shown on our website.

Right to erasure: You are entitled to get your data erased from our customer relationship management (CRM) databases. Please note that we need to retain certain information about you for legal and internal business reasons, such as fraud prevention. We will retain your personal information for as long as necessary to provide you with the services you are eligible to use and as needed to comply with our legal obligations and enforce our agreements. You can request that your data be deleted by using the current contact details shown on our website.

Right to object / restrict processing or both: You have a right to object/restrict the processing of your data in some circumstances, including where the data is inaccurate (for the period during which we are verifying the data), the data is no longer required in light of the purpose of processing, or in connection with direct marketing (you can prevent/discontinue marketing communications to you by sending a request using the current contact details shown on our website or by using the facility within the marketing communications themselves.

In the above cases, we will retain minimum personal data to note that you opted out from being contacted again.

Changes to the Privacy Policy

Our Services may change from time to time. As a result, we reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. If we make any material changes to the way we use or disclose your personal information, we will notify you by email, at the email address you have provided to us. If you object to any changes you must cease using our Services. Please review this Privacy Policy periodically by visiting this webpage. This Privacy Policy was last updated on the date indicated at the top of this page. Your continued use of our Services after any changes or revisions to this Privacy Policy indicates your agreement to the terms of the revised Privacy Policy. Merlin Scott Associates Limited welcomes your comments regarding this Privacy Policy. If you believe that we have not adhered to this Policy or If you have questions or concerns with respect to our Privacy Policy, please write to us at using the current contact details shown on our website.

Legitimate Interests Assessment

To comply with GDPR, Merlin Scott Associates Limited (MSAL) has carried out a Legitimate Interests Assessment which is documented below

Purpose of Processing

MSAL has a legitimate interest to process personal data relating to decision makers and budget holders in limited companies in the UK. The data is gathered from publicly available sources and directly from the companies concerned.

Lawful Business Objective

The processing is necessary in order to produce industry sector reports and for business-to-business marketing purposes; a lawful business objective specifically identified by the Privacy and Electronic Communications Regulations 2003 (PECR). Recital 47 of the GDPR identifies direct marketing as a legitimate use of personal information.

Reasonable Expectation

The data subjects are senior business people (company directors) with decision making and budgetary responsibilities and can reasonably expect to be contacted with marketing material relating to their professional roles.

Adequate, Relevant and Limited

The data collected is limited to names of senior managers and directors, their job titles, company addresses, company landline telephone numbers and corporate email addresses. If a person leaves their role, their name and contact details are deleted from the database.

Opt Out

If a data subject requests that their data is removed from the database, it is suppressed so that it cannot be accessed or added again at a later date.

Valuable Service

In supplying accurate, regularly updated reports, MSAL provides a valuable service to company directors. In the absence of MSAL and similar high quality service providers, company directors would have to rely on limited, inaccurate and out-of-date data for their decision making, which would have a detrimental effect on the success of their businesses and the wider economy.

MSAL has updated its privacy policy to show that we are relying on legitimate interests to process data.