Group Privacy Policy

Group Privacy Policy

MJH Group Holdings Limited, its subsidiaries and associated businesses (‘MJ Hudson’ and ‘we’) are committed to protecting your personal data and your privacy.  We endeavour to ensure that any personal data we collect about you will be held and processed strictly in accordance with the Data Protection Act 1998 (DPA) and, on and from 25 May 2018, the European General Data Protection Regulation (GDPR). The terms Personal Data, Data Controller and processing have the meanings given to them in the GDPR (which can be accessed here), unless otherwise indicated.

Which policy is relevant to your situation?

 At MJ Hudson, we collect and process Personal Data in a number of ways.  To help you find the information that is most relevant to your situation, we have separated our policy into a number of sections.  Please click on the [link] OR [heading] below that is appropriate for your situation to find out more.

  1. You are a client of MJ Hudson;
  2. You are a client of MJ Hudson-Allenbridge;
  3. You are applying for or enquiring about a job at MJ Hudson;
  4. You are an employee or contractor of MJ Hudson;
  5. You are a supplier or service provider to MJ Hudson.

 

 

This Privacy Policy demonstrates how MJ Hudson handle the Personal Data you provide to us, or which we collect about you, in the following ways (Your Data):

  • by you submitting information to us through our websites mjhudson.com or www.mjhudson-allenbridge.com for example, when you subscribe to our newsletter (Website User Data);
  • by you submitting information to us when you complete one of our surveys (Survey Data);
  • through your use of our other marketing resources, such as events or webinars which we run or sponsor (Marketing Data);
  • from what we learn about you from your visit to our websites (Website Background Data); and/or
  • by you otherwise interacting with us a prospective, current or former customer, (for example, where you provide your business card to us) other than in connection with ongoing legal services we are providing to you or your organisation (Prospect Data).

This statement does not apply to:

  • the collection and processing of Personal Data in the course of providing legal or other services to our clients. For information about privacy in the context of services provided to our clients, please contact the relevant MJ Hudson partner or person responsible for your matter.
  • the collection and processing of Personal Data about our employees or contractors. For information about privacy in the context of doing work for MJ Hudson, please see the employee handbook.
  • the collection and processing of Personal Data in relation to job candidates or applications for roles advertised on this website. For information about privacy in this context, click here.
  • the collection and processing of Personal Data on our suppliers or service providers. For information about privacy in this context, click here.
For the purposes of the DPA and the GDPR, MJ Hudson is the controller of Your Data.  If you have any queries regarding this policy or complaints about our use of Your Data, please contact us at data-processing@mjhudson.com or at the address below and we will do our best to deal with your complaint or query as soon as possible.

MJ Hudson Limited
8 Old Jewry,
London
EC2R 8DN

FAO: Data Processing

The table below sets out the purposes for which we may process Your Data and the legal basis for the processing:

Data Purpose Legal Basis
Website User Data 

Marketing Data

Prospect Data

 

To keep you informed of any activities undertaken by us which we believe may be of interest to you and this use may include sending you email and postal marketing from time to time or requests to respond to a survey Consent – this will be requested either when you submit Your Data to us or, if we have received Your Data indirectly, by way of an email sent prior to us sending you any marketing communications.
Website User Data

Website Background Data

 

Website analytic purposes.  For further details on the technology we use in order to analyse our website’s performance, please see our cookies policy here. Consent – this will be obtained when you click on the banner at the top of our website to accept certain cookies.Legitimate interest of MJ Hudson (see our cookies policy for further information)

 

Website User Data

Marketing Data

Prospect Data

To provide you with the newsletter(s) or information you have requested Performance of a contract
Website User Data

Marketing Data

Prospect Data

Website Background Data

Prospect Data

Survey Data

To respond to requests for information from regulated bodies or government agencies Compliance with a legal obligation
Website User Data

Prospect Data

 

To respond to an enquiry you have submitted Legitimate interest of MJ Hudson – it may be necessary for us to process Your Data in order to reply or respond to your enquiry
Survey Data To gather and analyse information on the market for our internal purposes which may be used to publish a report Consent – this will be requested when you submit Survey Data to us.
Survey Data To provide perception study services to our clients Performance of a contract

Please note that we may on occasion be required to share your information with the following categories of recipients:

  • MJ Hudson offices and branches and our associated firms. A full list of all of the entities within the MJ Hudson group is listed on our website.
  • Third parties who provide services on our behalf. For example, we use third parties such as MailChimp and GSuite to provide marketing automation services and Worldpay to provide payment processing services on our MJHudson-Allenbridge website. Our A full list of all our third party service providers is available on request.

We have taken steps to ensure that all such entities keep Your Data confidential and secure and only use it for the purposes that we have specified and have informed you of.  Our service providers are subject to data processing agreements which are, or are in the process of being updated to become, compliant with the requirements set out in the GDPR.  Further details regarding any third parties who are located outside the EEA are set out in paragraph 5 below.

In relation to any other third parties, we will only disclose your information in the following circumstances:

  • where you have given your consent;
  • where we are required to do so by law or enforceable request by a regulatory body;
  • where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights; and
  • if we sell our company, go out of business, or merge with another company.

In certain circumstances, we may transfer Your Data to countries outside the EEA, which may not adhere to the same levels of data protection to which countries within the EEA are subject.  Any such transfers are, at all times, made in accordance with the DPA and the GDPR.  Details of the circumstances and mechanisms in place to ensure compliance are set out below:

  • MJ Hudson Group Companies in the Channel Islands and South Africa

We have offices in Jersey and Guernsey in the Channel Islands.  Our central servers are also located in Jersey. The European Commission has ruled that both Jersey and Guernsey offer adequate levels of data protection in their domestic legislation and transfers to these jurisdictions are, therefore, permitted under the DPA and GDPR.

We also have an office in South Africa.  All Personal Data used by this office is held on MJ Hudson’s central servers located in Jersey.

  • Think Studio

We use Think Systems UK Limited (t/a Think Studio) to host and manage our website and to provide us with marketing automation services. Think Studio is based in the United Kingdom but use Campaign Monitor Pty Limited, located in Australia, to provide our marketing automation services.  If you have consented to us using Your Data to send you marketing communications, Your Data may be transferred to servers located in Australia.  Any such transfer outside the EEA is made in accordance with the Standard Contractual Clauses approved by the European Commission. Think Studio’s privacy policy can be viewed here and Campaign Monitor’s privacy policy can be viewed here.

  • SurveyMonkey

We use SurveyMonkey to carry out our online surveys.  SurveyMonkey stores survey data on its servers in the United States. SurveyMonkey Inc. (and its subsidiary company, Infinity Box Inc.) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework.  Transfers of Personal Data to SurveyMonkey in the United are therefore made subject to appropriate safeguards in accordance with the DPA and the GDPR. We have also put in place a Data Processing Agreement based on the Standard Contractual Clauses approved by the European Commission to provide enhanced protection for Your Data. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield website: https://www.privacyshield.gov/welcome.  SurveyMonkey’s privacy policy can be viewed here.

  • MailChimp

We use MailChimp to provide marketing automation services in relation to our MJ Hudson Allenbridge subscribers. If you subscribed through our MJ Hudson Allenbridge website or have consented to MJ Hudson Allenbridge using Your Data to send you marketing communications, Your Data may be transferred to MailChimp’s servers in the United States.  The company that operates MailChimp, The Rocket Science Group LLC, participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Transfers of Personal Data to MailChimp in the United States are therefore made subject to appropriate safeguards in accordance with the DPA and the GDPR. MailChimp’s privacy policy can be viewed here.

  • GSuite

We use Google’s GSuite to provide some marketing automation services in relation to our MJ Hudson Allenbridge subscribers.  If you subscribed through our MJ Hudson Allenbridge website or have consented to MJ Hudson Allenbridge using Your Data to send you marketing communications, Your Data may be transferred to Google’s servers in the Americas or Asia. Google, (including Google LLC and its wholly-owned US subsidiaries) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework.  Transfers of Personal Data to Google in the United are therefore made subject to appropriate safeguards in accordance with the DPA and the GDPR. We are also in the process of putting in place a Data Processing Agreement based on the Standard Contractual Clauses approved by the European Commission to provide enhanced protection for Your Data. Google’s privacy policy can be viewed here.

Your Data will be stored for a maximum period of 6 years, after which time it will be destroyed if it is no longer required for the lawful purpose(s) for which it was obtained. If you consent to marketing, any information we use for this purpose will be kept with us until you notify us that you no longer wish to receive this information. unless we request your consent to store it for a longer period.

  • Under the GDPR, you will have the following rights in relation to how we process Your Data:
    • Right to request access – you may obtain confirmation from us as to whether or not Your Data is being processed and, where that is the case, access to Your Data.
    • Right to rectification and erasure – you have the right to obtain rectification of inaccurate personal data we hold concerning you and to obtain the erasure of Your Data without undue delay in certain circumstances.
    • Right to restriction of processing or to object to processing – you may require us to restrict the processing we carry out on Your Data in certain circumstances or to object to us processing Your Data.
    • Right to data portability – you have the right to receive Your Data in a structured, commonly used and machine-readable format.
    • Right to withdraw consent – where you have provided your consent to us processing Your Data, you have the right to withdraw your consent at any time. This can be done by emailing data-processing@mjhudson.com at any time or by clicking the “unsubscribe” link on any marketing communications you receive from us.
    • Right to lodge a complaint – you may lodge a complaint with any supervisory authority in the EU. The supervisory authority for the United Kingdom is the Information Commissioner’s Office.

For further information on your rights, please see the Information Commissioner’s website here.

  • There is no statutory or contractual requirement for you to provide Your Data to us and you are not obliged to do so. Please note, however, that we may not be able to provide you with the services you have requested, such as to receive our newsletter, if you do not provide your contact details.  As set out in our cookies policy, our website may not be able to function fully if you do not agree to certain cookies being set on your computer.
  • We do not undertake automated decision-making or profiling on Your Data.
  • We keep our privacy policy under constant review and may change it from time to time to reflect our practices or to remain compliant with relevant legislation. We will notify you of any material changes to our privacy policy via a notification on our website. Your continued use of this website or our other marketing services, following the posting of changes to these terms, will mean you accept these changes

We recognise the need to ensure that personal information gathered via this website remains secure. Our site has security measures in place to protect against the loss, misuse and alteration of the personal information under our control. Our security measures include the use of a hardware firewall to prevent unauthorised access. You acknowledge that although we exercise adequate care and security there remains a risk that information transmitted over the Internet and stored by computer may be intercepted or accessed by an unauthorised third party.

Participation in our surveys is entirely voluntary and, by submitting your responses, you are consenting to use collecting and processing Your Data in accordance with this Privacy Policy.  We will never share Survey Data with third parties (other than SurveyMonkey as set out in 5.5 above) and all data is amalgamated and anonymised before the results of the survey are published. In most circumstances, we do not collect the name or contact details of our respondents and this is only provided voluntarily by the respondent if they wish to be entered into a prize draw, so that we can contact them with their prize.

Some of your responses to our surveys may include Personal Data which falls within the definition of “Special Category Data” for the purposes of the GDPR.  For example, your responses may reveal your ethnicity or race or your political opinions. Where a question requires an answer that may include Special Category Data, we will request your explicit consent to our processing this data in accordance with this Privacy Policy, before you submit your response.

Please note that in certain circumstances, we also undertake surveys on behalf of our clients (Client Surveys).  The Personal Data we collect through Client Surveys is held in accordance with this Privacy Policy and is anonymised prior to us creating our report.  We never share your Survey Data with our clients.

In some circumstances, we may obtain Personal Data about you from other sources.  This information may include your name, contact details and job title, which we obtain from third party sources such as Preqin, organisers of events we sponsor or other publicly available sources, such as your company’s website.

Our website contains links to other websites belonging to third parties. We do not control the privacy practices of these other websites. You should therefore make sure when you leave our website that you have read that website’s privacy policy.

 

Please note that we are in the process of updating our policy regarding client Personal Data in order to ensure that it is compliant with the GDPR before May 2018.  Please contact the MJ Hudson partner responsible for your matter or contact us at data-processing@mjhudson.com for further information.

Please note that we are in the process of updating our policy regarding client Personal Data in order to ensure that it is compliant with the GDPR before May 2018.  Please check our website again at a later date or contact us at data-processing@mjhudson.com for further information.

Please note that we are in the process of updating our policy regarding job candidate Personal Data in order to ensure that it is compliant with the GDPR before May 2018.  Our current privacy policy is available here.

Please refer to the privacy policy set out in your employee handbook for information on how we protect Personal Data relating to our employees and contractors.

Please note that we are in the process of updating our policy regarding supplier Personal Data in order to ensure that it is compliant with the GDPR before May 2018.

Our current privacy policy is available here

Please note that we are in the process of updating all of our policies in order to ensure they are compliant with the GDPR before May 2018.  Some of the information in this policy may, therefore, be temporarily unavailable.  If this is the case, please check our website again at a later date or contact us at data-processing@mjhudson.com.