Privacy Policy

This privacy policy (Policy) sets out how We process any personal data We collect from You or that You provide to Us through Our Services.  By using this website or our services, You consent to these practices.

 

a) Terminology


For the purpose of this Policy We have clarified the use of certain words, clarified words are capitalised when used in text to notify the reader that We have provided specific interpretation.

We/Us/Our and Ourselves - refers to the entity known as MTL & Co. Holdings Ltd, a private company headquartered in London, England. 

Site - refers to any website created or operated by or on behalf of Ourselves.

Trademarks - refers to all trademarks, logos, or service marks owned by Us, whether registered or unregistered.

Content - refers to all content, such as images, text, design and layout, charts, diagrams, and audio and video files.

Services - refers to any site, application, mobile app, web application or product created or operated by or on behalf of Ourselves including any and all content we provide on these service platforms.

You/Your - refers to any person, company, or other entity reading or accessing these terms, or any part of Our Content, and/or using or accessing any part of Our Site or Our Services.

Device - refers to any electronic device capable of communicating with Our servers or accessing Our Services, including computers and mobile phones.

Direct Correspondence - Correspondence with email addresses, physical addresses registered to MTL & Co. Holdings Ltd, or through Our 'Contact Us' section below.

 

b) Foreword


We reserve the right to modify or entirely replace this Policy at any time without prior warning or notification of change. Changes to this Policy will become effective immediately and will affect how We process any new information. Providing Us with personal information or continuing to use the Site after changes have been made constitutes Your acceptance of the modified Policy. Therefore, it is important to check back regularly to ensure You remain in accordance with Our practices.

Our Site is operated by and on behalf of Us, We are a company registered in England and Wales with company registration number 11849763. Further details of Our registered company can be found on the Companies’ House website. If You would like to contact Us, please use our 'Contact Us' section below.

 

c) The Data We Collect

Your information can either be held by Us, or by You in files called cookies, in both cases either We or third parties may view and process the information stored.

 

i) Purposes


We need to collect Your data for a variety of reasons including to comply with local law, where it is necessary for pursuing legitimate interests, and to be able to send and receive communications. This section details the legal basis for Our collecting Your data.

 

Feedback

We retain the information and meta data of all direct communications we receive, this includes information given by You through Direct Correspondence, in polls/user feedback sections, and elsewhere. This information is retained for the explicit purpose of professional communication between You and Ourselves, and for improving Our Services. The lawful basis for Our processing of this information can be found in Article 6(1)(a) of the UK GDPR:

“the data subject has given consent to the processing of his or her personal data for one or more specific purposes”

 

Analytics

Analytics data, such as the data processed by Google Analytics on behalf of Us, is used to investigate how users interact with the site in general and how We can improve our services, which provides the lawful basis for Our processing of this information under Article 6(1)(f) of the UK GDPR:

“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”

 

Financial Data

We collect and store financial information, including on donations and e-commerce, for Our company records, for tax purposes, and in order to comply with Our legal obligations, which provides the legal basis for Our lawful processing of this data under Article 6(1)(c) of the UK GDPR:

“processing is necessary for compliance with a legal obligation to which the controller is subject”

 

Preferences

Site preferences, including themes, cookie preferences, search functionality and other visual settings, may be collected when You interact with Our website. Some of the collected data may be stored in cookies on Your computer, please see our Cookie Policy below for more details. The lawful basis for Our processing of this information can be found in Article 6(1)(f) of the UK GDPR:

“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”

 

Contributor Details

Contributors, including donors and data populators can consent to have their name displayed on Our website to thank You for Your contribution. This name is provided separately to Us by You, which provides the legal basis for Our lawful processing of this data under Article 6(1)(a) of the UK GDPR:

“the data subject has given consent to the processing of his or her personal data for one or more specific purposes”

 

ii) Retention Period

All data, including feedback, analytics, financial data, preferences, and contributor details are stored indefinitely or until the purpose for which the data was initially collected no longer applies. For example, we are required to keep financial data, such as invoices, for a period of 6 years after receipt. However, this does not mean that we will delete such financial data after 6 years as we may consider it in our interests to retain our financial record.

 

iii) Your Rights

The rights You have over Your data are absolute, uninfringeable and include any data You have provided. However, We retain the right to refuse requests where doing so would breach our legal obligations or if the request is impossible. For example, if it concerns usage data that has been anonymised. To exercise Your rights you must contact Us using Direct Correspondence (click here), and provide Your name and contact details so We can ensure all of your personal data is captured.

  1. You have a right to receive an exported file of the personal data held about You. 
  2. You have a right to rectify any information We hold about You that is false.
  3. You have a right to have any information We hold about You deleted. 
  4. You have a right to object to Us processing your data. After objecting you must permanently discontinue usage of Our Services.

Requests for additional copies of Your data, or requests that are manifestly unfounded or excessive will be subject to an administrative fee of no less than £100 sterling.

 

iv) Third-Party Data-Processors

We use Google Analytics to track user interaction with the website and to improve Our services, additionally users may be checked through automated services such as spam, DDoS, and threat detection services like CloudFlare. Traffic and users who are redirected through such sites are subject to their terms of use and privacy policy. We bear no responsibility for how these third parties treat or process Your data.

 

d) Cookie Policy


As previously stated, We use cookies (small files that store some information on Your system) to operate Our services. These cookies generally fall into two categories: essential cookies and analytics cookies.

 

i) Necessary Cookies

Necessary cookies cannot be turned off as they provide core functionality for the website. For example, a cookie is required to store cookie preferences. Without mandating such a cookie, We would have to display the cookie banner on every page and it would be impossible to follow the spirit of the UK GDPR regulations. You may disable or delete these cookies Yourself by using your browser settings.

 

ii) Analytics Cookies

We use third party cookies and data analytics tools to monitor site usage and improve Our website.

You can opt in or out of analytics (non-necessary) cookies by clicking the below toggle, or adjusting your browser settings.

Non-essential cookies are currently disabled!

e) Complaints


If you are unsatisfied with Our Policy, or if you believe We have made a mistake, please contact Us. We are happy to revaluate Our decision making process and try to arrive at a resolution. If We do not satisfactorily resolve the matter, or if We do not resolve the matter in a timely manner, you may also raise a complaint with Your relevant supervisory authority. Additionally, since We are based in the UK, you may wish to raise Your complaint with the Information Commissioner's Office (ICO). You can find their contact details here, or call them directly on 0303 123 1113.