The Middle Six understands that you care about how information about you is collected, used, and shared, and we appreciate that you trust this information with us. We take your privacy very seriously and are committed to protecting your information. We act in accordance with applicable data protection and privacy laws when collecting and using information about you.
Should you have any comments or questions about how we collect and use your personal information, please reach out via email to firstname.lastname@example.org.
This Site is not intended for individuals under the age of 18. We do not knowingly collect personal information directly from individuals under 18 years of age. Our services are not intended for individuals under 18 years of age. If you are under 18 years of age, you should not submit or post personal information on our Site.
- Key Terms. It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||The Middle Six|
|Personal information||Any information relating to an identified or identifiable individual|
- Personal Information Collection and Use. We collect information about you and your use of this Site through various means, including information we receive from you on Site forms, as well as through your access, use, or interaction with this Site. Such processing is utilized to provide this Site to visitors.
Please do not submit any confidential, proprietary, or sensitive personally identifiable information (e.g., Social Security Number or Driver’s License Number) to us through this Site. We are not liable or responsible for any consequences resulting from the submission of this personally identifiable information through this Site. If you do submit this information, you do so at your own risk.
Where we gather your information using consent, your opt-in consent will be clearly obtained. You may withdraw this consent at any time by contacting us at email@example.com.
- Personal Information We Collect About You.We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
|Categories of Personal Information||Specific Types of Personal Information Collected by The Middle Six|
|Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)||Name, email address, phone number.|
|Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.||Name, email address, phone number.|
|Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)||We do not collect.|
|Biometric information||We do not collect.|
|Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)||The information we collect could be aggregate and/or user-specific individual information but does not reveal your specific identity (like your name and/or contact information). This information is primarily needed to maintain the security and operation of our Site and for internal analytics and reporting purposes. This information includes device characteristics (including operating system and name), your IP address, browser characteristics, communication data, referring URLs (what web websites or search terms that referred you to the Site), how and when you use our and other technical information, time zone, location, country, language preferences and patterns of use (information on the individual web pages or services you view on our Site, and browsing and navigation patterns within our Site).|
|Geolocation data||We do not collect.|
|Audio, electronic, visual, thermal, olfactory, or similar information||We do not collect.|
|Professional or employment-related information||We do not collect.|
|Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)||We do not collect.|
|Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||We do not collect.|
This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.
- How Your Personal Information is Collected. We collect most of this personal information directly from you—by email and/or via our Site. However, we may also collect information:
- Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
- From cookies on our Site;
- Google Analytics*; and
- Via our IT systems, including automated monitoring of our Site and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.
* Google Analytics uses persistent cookies to allow The Middle Six to see behavior information relating to visitor age, gender, and interests. Athena may also use this data to create remarketing lists. You can opt out of Google Analytics without affecting how you visit this Site. For more information on opting out of Google Analytics tracking and customizing Google Display Network ads, visit Google’s Ad Settings.
- How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:
- To comply with our legal and regulatory obligations;
- For our legitimate interests or those of a third party; or
- Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To prevent and detect fraud against you or The Middle Six||For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you|
|Conducting checks to identify our customers and verify their identity
Screening for financial and other sanctions or embargoes
Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator
|To comply with our legal and regulatory obligations|
|Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g., policies covering security and internet use||For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best product|
|Operational reasons, such as improving efficiency, training, and quality control||For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best product|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
|Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product and/or service range or other efficiency measures||For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price|
|Preventing unauthorized access and modifications to systems||For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
|Updating and enhancing customer records||For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
|Marketing our services and those of selected third parties to:
¾ existing and former customers;
¾ third parties who have previously expressed an interest in our services;
¾ third parties with whom we have had no previous dealings.
|For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers|
|External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts||For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal and regulatory obligations
The above table does not apply to special category personal information, which we will only process with your explicit consent.
- Do Not Track. Most web browsers and some mobile operating systems and mobile applications include a “do not track” feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored or collected. Our web services do not alter, change, or respond upon receiving Do Not Track (DNT) requests or signals in browsers. As described in more detail above, we track user activity using cookies and similar technologies.
- Who We Share Your Personal Information With. We routinely share personal information with:
- Business partners – These are businesses that we work with to offer you certain services or promotions.
- Non-affiliated service providers – These non-affiliated service providers may offer services like, but not limited to, payment processing, data analysis, email delivery, hosting services, customer service, marketing efforts, etc. These companies may use information about your visits to this Site and other websites that are contained in cookies to provide services, advertisements, or to collect data about how you interact with this Site over time
- Government and regulatory authorities – We may provide information to government and regulatory bodies to provide the services you have purchased or because of legal and regulatory obligations on our business.
- Auditors and financial and legal advisors – We may need to provide information to assist with provision of services or management of our business.
- Relevant industry self-regulatory bodies – We may need to provide information to assist with provision of services or management of our business.
- Others only as permitted by law
We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We do not sell your personal information, and we have contracts with service providers to prohibit any sale of your personal information and to provide written assurances regarding the security and privacy protections they have in place to protect your personal information.
- Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
- Identifiers (e.g., a real name, email address, or other similar identifiers);
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, telephone number;
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
- Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Where Your Personal Information is Held. Information may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).
- How Long Your Personal Information Will Be Kept. We will keep your personal information while you work with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly; or
- To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.
- Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
|Disclosure of Personal Information We Collect About You||You have the right to know:
· The categories of personal information we have collected about you;
· The categories of sources from which the personal information is collected;
· Our business or commercial purpose for collecting or selling personal information;
· The categories of third parties with whom we share personal information, if any; and
· The specific pieces of personal information we have collected about you.
Please note that we are not required to:
· Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
· Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
· Provide the personal information to you more than twice in a 12-month period.
|Personal Information Sold or Used for a Business Purpose||In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
The categories of personal information that we disclosed about you for a business purpose.
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, email firstname.lastname@example.org.
|Right to Deletion||Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
· Delete your personal information from our records; and
· Direct any service providers to delete your personal information from their records.
· Please note that we may not delete your personal information if it is necessary to:
· Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
· Debug to identify and repair errors that impair existing intended functionality;
· Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
· Comply with the California Electronic Communications Privacy Act;
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
· Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
· Comply with an existing legal obligation; or
· Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
|Protection Against Discrimination||You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
· Deny goods or services to you;
· Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
· Provide a different level or quality of goods or services to you; or
· Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
- Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
- Email us at email@example.com.
Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact directly by email or phone, you will need to provide us with:
- Enough information to identify you (e.g., your full name, address and customer or matter reference number));
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility bill); and
- A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
- Linking to Third Parties. When you leave this Site and go to another linked website, we are not responsible for the content or availability of the linked website. Please be advised that if you enter into a transaction on the third-party website, we do not represent either the third party or you. Further, the privacy and security policies of the linked website may differ from those practiced by us.