Last updated September 2018
This policy aims to give you information on how Melu collects and processes your personal data through your use of our Live Chats, located on our website meluchat.com or on our clients' websites. This policy sets rules applicable to all information collected by us from which you can be identified.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1 & 3 Kings Meadow, Osney Mead, Oxford OX2 0DP
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.
1. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes your full name and date of birth;
- Contact Data includes your addresses and telephone numbers;
- Customer Data includes any other identifiable data contained in the answers you have submitted on our Live Chats;
- Technical Data includes internet protocol address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;
- Usage Data includes information about how you use our website 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 in law as this data will not directly or indirectly reveal your identity.
In the course of our Live Chat session, we may collect Special Categories of Personal Data about you, especially health or medical information. However, we won't collect any Special Category Data without your explicit consent.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
2. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your personal data by using our Live Chat on meluchat.com and Live Chats located on our clients' websites, filling in forms or by corresponding with us by post, phone, email or otherwise.
- Third parties. We will receive personal data about you from various third parties as set out below:
- our clients;
- analytics providers; and
- search information providers.
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 we need to comply with a legal obligation
- Where you have given us consent to process your personal data,
- Where we need to perform the contract we are about to enter into or have entered into with you,
- 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.
OUR LEGITIMATE INTERESTS
Legitimate interests means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure 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.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We process data on behalf of our clients to provide them with a Live Chat service and facilitate contact with you. With our Live Chat service, we communicate with you through real-time conversations to facilitate contact with companies for which you have shown interests for.
Please read our clients' privacy policies located on the website where you started using the Live Chat to see how your personal data is used by them.
Please read below a description of all the ways Melu plans to use your personal data, and which of the legal bases we rely on to do so.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To provide our services to our client, we use personal data collected through our Live Chats||(a) Identity
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
|(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how chat users act towards our services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To use data analytics to improve our website, services, marketing, client relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
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 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.
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 for the purposes set out in the table above with the following third-parties:
- Our group companies. Melu is a trading name of Tonic Box Limited. We are part of 24Data Inc. We may share personal data with other companies in the group who are based in the United States and in the United Kingdom, to run our business and provide our services to you. Please read 5 ‘International transfers' below to see how we protect your personal data abroad.
- Our clients. We may share your personal data with our clients if you are pre-qualified as a lead for them. Our clients may then use your data to make contact with you.
- Specific third parties.
- Service providers who provide IT and system administration services such as Liquid Web.
- Professional advisers including lawyers, bankers, auditors and insurers based in the United States and the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom.
- Other third parties. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
5. International transfers
We share your personal data within the 24Data Limited group. This will involve transferring your data outside the European Economic Area (‘EEA').
We ensure your personal data is protected by requiring all our group companies to follow the same standards of protection when processing your personal data.
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- We may also transfer data to providers and partners based in the US who are part of the Privacy Shield framework.
6. Data security
We endeavour to take all reasonable steps to protect your data. We have implemented appropriate technical and organisational measures to ensure security of processing. Computer systems are protected by up-to-date anti-virus software and encrypted on secure databases. Access to your personal data by staff is protected by unique passwords. Our staff and associates are under strict obligations of confidentiality and only relevant staff and our approved third parties have access to your data.
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
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.
Therefore, unless we are obliged to hold your personal data, it will be deleted 6 months after you have been registered in our systems.
We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8. YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data. 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:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at:
1 & 3 Kings Meadow, Osney Mead, Oxford OX2 0DP
We may 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).
We try to respond to all legitimate requests 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.