Last updated: 21 June 2021
1. MADE.COM’S APPROACH TO PRIVACY
1.1 www.corporate.made.com is a website owned and operated by Made.com Group Plc of 5 Singer Street, London, EC2A 4BQ (company number 13346124) (“we”, “our”, “us”). We are committed to protecting and respecting your privacy in accordance with the applicable data protection legislation (the "Data Protection Legislation"). This privacy policy (“Privacy Policy”) sets out how we collect, use and share information that identifies you or is associated with you (“personal data”). For information about how we process consumer data, please see our consumer privacy policy available here.
1.2 For the purposes of the Data Protection Legislation, we are the data controller of the personal data we collect and process about you. If you have any questions related to this Privacy Policy, please use the contact details provided in section 10 below to get in touch.
1.3 You should also be aware that we use cookies to store and access information whilst providing access to our website. You can find out more about our use of cookies in our Cookie Declaration.
2. WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?
2.1 We collect personal data from you when you voluntarily submit information directly to us or via our website. This includes your country of residence to enable access to documentation on the website and your contact details to circulate Regulatory News Service (RNS) alerts via an automated email alert service where you have actively opted in to receive such information. We also automatically collect personal data indirectly from you such as information about the pages you look at on the website or the device you use to connect to the website (see our Cookie Declaration for further details about personal data that we collect automatically).
2.2 We have appointed Equiniti Limited (“Equiniti”) whose registered office is at Aspect House, Spencer Road, Lancing BN99 6DA (company number 6226088) to manage the register of members of Made.com Group Plc in accordance with the Companies Act 2006. Equiniti’s role as registrar includes keeping an up-to-date record of shares held by shareholders, managing share allotments and transfers, issuing share certificates (as applicable), administration and dividends and supporting other regulatory functions. In carrying out registry services, Equiniti processes personal information about you as a shareholder on behalf of Made.com Group Plc. We direct you to Equiniti privacy notice for more information how Equiniti processes your personal data when you use their website or online services directly, available here.
2.3 If you are a shareholder, we will collect and use personal information such as your name and address, bank account information, email addresses, date of birth and death (if applicable), the number of shares held and phone number. This personal information is collected when you provide details to us directly or through your agent, stock broker or via Equiniti.
2.4 We will use your personal data (with the support of our registrar, Equiniti) for the specific purpose of administrating and maintaining our share register and related functions, which will include:
(a) the accurate documentation of shareholders, including allotments and transfers, in the company’s register of members;
(b) the production and distribution share certificates (as required);
(c) dividend planning, payment and distribution;
(d) the provision of voting and meeting management services for AGM/EGM and if required Court Meeting or Class Meetings; and
(e) producing share register analysis reports, which identify and track fund manager and beneficial shareholder movements across the share register in accordance with regulatory requirements.
2.5 Wherever we collect or use personal information relating to our register of members, this will be for at least one of the following purposes:
(a) to meet responsibilities to regulators, tax officials, law enforcement, or other legal responsibilities;
(b) to manage your shareholder rights and our obligations to you as a shareholder;
(c) to operate and improve our business and keep shareholders informed about our products and services.
2.6 We may share your data with third parties in accordance with Section 10 (including with Equiniti as our service provider) and with payment providers assisting in the administration of dividend payments, proceeds of share sales or other relevant payments to and from shareholders.
2.7 We may anonymise and aggregate any of the information we collect (so that it does not identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis and improving the website.
2.8. We process your personal data (i) with your consent, (ii) when we need to do this to fulfil a contract with you (iii) where we are required to do this by law (for example, to manage the register of members of Made.com Group Plc), and/or (iv) when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, we have a legitimate interest to use data analytics to improve our website.
3. INFORMATION WE SHARE WITH THIRD PARTIES
3.1 We may share your personal data in accordance with section 2.5 and with the following parties:
(a) Companies in the same group of companies as us: our subsidiaries (i.e. any organisation we own or control) or our ultimate holding company (i.e. any organisation that owns or controls us) and any subsidiaries it owns. These companies will only use your personal data in the same way as we can under this Privacy Policy.
(b) Service providers and advisors: third parties who provide a service to us or advise us. For example, we use Equiniti to manage the register of members of Made.com Group Plc. These third parties will only be allowed to use your personal data in accordance with our instructions and will be required to keep your information secure.
(c) Purchasers of our business: personal data may be disclosed or transferred to buyers or prospective buyers of our business or any of our assets as part of the sale.
(d) Law enforcement, regulators and other parties for legal reasons: third parties who we are under a legal obligation to disclose your personal data to or who we need to disclose your personal data to protect our rights, property or safety or the rights, property or safety of others, detect and investigate illegal activities and breaches of any agreement we have with you.
4. STORING AND TRANSFERRING YOUR PERSONAL DATA
4.1 International Transfers of your Personal data: the personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in, including, in particular, outside the European Union. Some of these jurisdictions offer differing levels of protection in respect of personal data and may, in certain instances, be less protective than the jurisdiction you are resident in. We ensure that your personal data is treated securely and in accordance with this Privacy Policy.
4.2 We put in place approved standard contractual clauses or rely on alternative transfer mechanisms to protect this data. A copy of these clauses is available for your review upon request to us using the contact details provided in section 10 below.
5. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA
5.1 You may have various rights with respect to our use of your personal data:
- Cookies: Please see our Cookies Declaration for more information about your rights as regards our use of cookies.
- Access, rectify, port, block, complete, delete and update: You have the right to access, rectify, block, port, complete, delete and update your personal data, and to restrict its use. You also have the right to request further information about the processing of your personal data.
- Object: In certain circumstances, you also have the right to object to the processing of your personal data by us.
5.2 You can exercise the above rights by contacting us using the details provided in section 10 below at any time. All requests will be dealt with at the earliest opportunity and any delay will be kept to a minimum.
5.3 There are exceptions to these rights; for example, access may be refused if it would reveal personal data about another person or if we are prevented from disclosing such information by law.
5.4 We hope that we can satisfy queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to the competent data protection authority.
5.5 When we ask you to supply us with your personal data we will make it clear whether the data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any information we ask for is optional.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
6.1 We will retain your information, whether or not your account is active, for as long as we believe it is necessary to fulfil our business purposes or to comply with applicable law, audit requirements, regulatory requests or orders from competent courts.
7. LINKS TO THIRD PARTY SITES
7.1 The website may, from time to time, contain links to and from third party websites of our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
8. CHANGES TO THIS POLICY
8.1 We may update this Privacy Policy from time to time, and when we do so we will update the “last modified” date at the top of this Privacy Policy. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.
9. NOTICE TO YOU
9.1 If we need to provide you with information about something, whether for legal, or business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the website. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.
10. CONTACTING US
10.1 Questions, comments and requests regarding this Privacy Policy are welcome and should be addressed to privacy@made.com or Made.com Group Plc, 5 Singer St, London, EC2A 4BQ, Attn: Privacy Manager.