Privacy Policy

Introduction

Welcome to Macsteel Global Limited's privacy policy.

Macsteel Global Limited respects your privacy and is committed to protecting your personal data in accordance with applicable laws, rules, regulations, directives and governmental requirements relating in any way to the privacy, confidentiality, security, integrity and protection of personal data, including the Data Protection Act 2018, the UK General Data Protection Regulation, the EU General Data Protection Regulation, and any EU Member State national implementing legislation (together, "UK GDPR"). This privacy policy will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you, however has been drafted to comply with UK GDPR. Therefore, the obligations described in this privacy policy and the rights of users set out herein may not be applicable to your jurisdiction.

Please use the Glossary below to understand the meaning of some of the terms used in this privacy policy. Where not defined, any defined terms will have the same meaning as in the UK GDPR.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Macsteel Global Limited collects and processes your personal data through your use of this website.

It is important that you read this privacy policy together with any other privacy policy 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 policy supplements other notices and privacy policies and is not intended to override them. Any relevant privacy policy or notice that should be read in conjunction with this policy is publicly available on our site under "Terms & Conditions".

Controller

Macsteel Global Limited is the controller under UK GDPR and responsible for your personal data (referred to as "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

Email address: macgloballtd-info@mitgr.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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 using the contact details above.

Changes to the privacy policy and personal data we hold

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. We discuss your right to notify us of inaccuracies below.

Third-party links

This website may include links to third-party websites (including websites of entities within our corporate group), 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 and, in relation to the data (including personal data) collected by such sites, plug-ins and applications, those privacy statements shall apply in place of our privacy policy. When you leave our website, we encourage you to read the privacy policy of every website you visit to understand how your data may be collected, processed and shared.

2. The data we collect about you

Personal data means any information about an individual from which that person could or can be identified. It does not include data where the possibility of identifying an individual has been rendered sufficiently remote (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Technical Data includes internet protocol (IP) address for the purpose of identifying your location.
• Usage Data includes information about how you use our website, products and services.

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 under UK GDPR 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 website 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 policy.

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.

Restricting collection of personal data

Please refer to our cookie policy for information on restricting the use of the types of cookies that operate on our website.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• 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 need to comply with a legal obligation.

Please refer to the Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, including how to restrict their use, please see our cookie policy.

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.

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 or otherwise obtain your consent.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosures of your personal data

We may share your personal data with the Internal Third Parties and/or the External Third Parties, as set out in the Glossary, for the purposes set out in the table Purposes for which we will use your personal data above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the applicable law via contractual means. We do not allow our third-party service providers 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.

5. International transfers

We share your personal data with the Internal Third Parties and/or the External Third Parties, some of which might involve transferring your data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed by the Information Commissioner's Office ("ICO") to provide an adequate level of protection for personal data; or
• Where we have carried out an appropriate transfer risk assessment, the scope of which is reasonable and proportionate taking into account the risk inherent in the data being transferred, the amount of data being transferred and the resources available to us as a controller, for each category of personal data of which we are making repeated or similar transfers; and
• We have adopted the ICO's International Data Transfer Agreement.

6. Data security

We have put in place appropriate technical and organisational 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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.

7. 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.

8. Your legal rights

Subject to your jurisdiction, you have rights under data protection laws in relation to your personal data. Please note that there may be limitations on these rights, depending on the specific circumstances concerning your personal data and the applicable law. Subject to applicable exemptions, Data Subjects covered by GDPR have the following rights:

• Request access to your Personal Data and be provided with information in relation to that data to ensure it is being lawfully processed. Please contact us for further instructions on making such a request and note that the ICO provides a template.
• Rectification of any incomplete or inaccurate data held about you by us (although we may need to verify the accuracy of any new data provided);
• Erasure of Personal Data where there is no compelling reason for us to continue to process it; where you have successfully exercised your rights to object to processing (below), where we have processed Personal Data unlawfully or where we are required to erase your Personal Data to comply with GDPR. Please note that we can refuse to delete or remove Personal Data where we require information for defence of legal claims;
• To restrict processing of Personal Data; you may exercise this right where (i) you are requesting rectification, in which case processing is suspended until the information is verified, (ii) we are processing your Personal Data unlawfully and as an alternative to exercising your right to request erasure, (iii) we no longer need to process your Personal Data but you need the Personal Data for the establishment, exercise or defence of legal claims; or (iv) you have exercised your right to object to processing of Personal Data which relies on legitimate interests as a basis for lawful processing, and we need to verify that we have such legitimate interests;
• Object to processing of Personal Data on the basis that it impacts on your rights and freedoms, however in some cases we may demonstrate that we have compelling legitimate grounds to process Personal Data which overrides your rights and freedoms or where we require that information for defence of legal claims;
• To receive a copy of Personal Data in a machine-readable format or request the transfer of Personal Data to another party;
• 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; and
• To not be subject to automated decision-making, including profiling, which has a legal or other significant effect on you.

If you wish to exercise any of the rights set out above, please contact us via the methods set out in this privacy policy.

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 or excessive or in the event you request multiple copies of personal data to be provided to you. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We will 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 promptly and in any event 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.

Please note that, where we have requested information relating to identity and/or to clarify your request, the time for us to respond will run from the moment such information is provided to us.

9. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure website experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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.

THIRD PARTIES

Internal Third Parties means the companies within the Macsteel Global Limited group.

External Third Parties means a service provider acting as a processor based outside of the UK who provides data analytics reporting services to us based on the operation of Google Analytics on our website.