M&C Saatchi Mobile Limited [t/a M&C Saatchi Performance] and each of its affiliated entities as may exist globally from time to time, wants you to be familiar with how we collect, use and disclose information. We will let you know which entity will be the controller for your data when you purchase a product or service with us. M&C Saatchi Performance is the controller and responsible for this website.
“Personal Data” is information that identifies you as an individual or relates to an identifiable individual, including:
We may need to collect and process these types of Personal Data in order to provide the requested Services to you, or because we are legally required to do so, or because such information is of particular importance to us and we have a specific legitimate interest under law to process it. We have a legitimate interest in collecting and processing Personal Data, for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business across M&C Saatchi Performance; and (3) to prevent fraud. If you do not provide the information that we request, we may not be able to provide you with the requested Services. 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.
We and our service providers may collect Personal Data in a variety of ways, including:
We and our service providers may use Personal Data for our legitimate business interests, including the following:
Your Personal Data may be disclosed:
We may also use and disclose your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (d) to protect your vital interests or the vital interests of another person.
In addition, we may use, disclose or transfer your Personal Data to a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, shares or stock (including in connection with any insolvency, bankruptcy or similar proceedings).
“Other Information” is any information that is not Personal Data and does not reveal your specific identity or does not directly relate to an identifiable individual, such as:
If we are required to treat Other Information as Personal Data under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Data as detailed in this Policy. For example, information such as IP address and location data constitutes Personal Data under the law applicable in EU jurisdictions.
We and our service providers may collect Other Information in a variety of ways, including:
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Data. If we do, we will treat the combined information as Personal Data as long as it is combined.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organisations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organisations through or in connection with the Apps or our Social Media Pages.
We seek to use reasonable organisational, technical and administrative measures to protect Personal Data within our organisation. 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. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
We give you choices regarding our use and disclosure of your Personal Data for marketing purposes. You may opt-out from:
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
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.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
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.
If you would like to exercise any of your rights noted above, you may contact us at:
M&C Saatchi Performance – London
36 Golden Square, London,
T: +44 207 543 4500
In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. 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, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances
Please note that we may need to retain certain information for recordkeeping purposes. There may also be residual information that will remain within our databases and other records, which will not be removed.
The Services are not directed to individuals under the age of 16, and we do not knowingly collect Personal Data from individuals under 16.
Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers. We may share your Personal Data within our group company and this will involve transferring your data outside the UK.
We ensure your Personal Data is protected by requiring all our group companies to follow the same rules when processing your Personal Data. These rules are called “binding corporate rules”. Many of our external third parties are based outside the UK so their processing of your Personal Data will involve a transfer of 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:
M&C Saatchi Performance
36 Golden Square, London
T: +44 207 543 4500
We ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., national insurance or social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
M&C Saatchi Performance
36 Golden Square, London,
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.