MASABI
PRIVACY POLICY
1. INTRODUCTION
Welcome to Masabi.com. Masabi Limited (“we”, “us”, “our” or “Masabi”) the owner and operator of Masabi.com, is committed to protecting and respecting your privacy.
This Privacy Policy explains:
- why and how we may use the personal information that we have obtained from interactions you (or others) may have with us as a business, including when you visit and use our website currently located at masabi.com (“Masabi Website”) or when you contact us;
- with whom we share your personal information; and
- the rights you have in connection with the information we use.
Please read the following carefully.
Masabi Limited is the controller of your personal information. This means that Masabi Limited decides why and how your personal information is processed. Please see the section at the end of this Privacy Policy for our contact and legal information.
In addition, we sometimes work with other organisations in connection with some of the processing activities described in this notice, such as social media platforms and our US group company Masabi LLC. Where that information is collected and sent to other organisations for processing that is in both our and their interests, and for a common purpose or purposes, we will be making decisions together in relation to that particular processing and will be ‘joint controllers’ with the organisations involved. As joint controllers, we and the other organisations involved in making these decisions will be jointly responsible to you under data protection laws for this processing.
Please note, this Privacy Policy does not apply to processing for our Justride product, for which we are a ‘data processor’. You can find out more information regarding how our customers use your personal information in respect of this product by contacting them directly. We are not responsible for the privacy or data security practices of our members/customers, which may differ from those explained in this Privacy Policy.
This Privacy Policy may change from time to time so please check this Privacy Policy occasionally to ensure that you are happy with any changes. For more information on changes to our Privacy Policy, please see paragraph 12 (Changes to this Privacy Policy).
This Privacy Policy was last updated on the date set out at the end of this Privacy Policy.
2. PERSONAL INFORMATION WE COLLECT ABOUT YOU
When you browse the Masabi Website, sign up to our newsletter on the Masabi Website, download content, contact us, request a demo of our products, interact with our staff including at meetings, events and pitches, purchase our products (including on behalf of your employer), interact with emails we send to you or apply for a job or interact with the careers page on/via the Masabi Website, we may collect personal information about you, including:
- Contact information – your name, email address, phone number, mailing address, marketing preferences and other information that enables us to contact you;
- Employment information – your company/employer’s name, title, role, CV/resume and other information relating to your employment or employment history; and
- Enquiry information – information included within and relating to your contact/enquiry/request for a demo.
Personal information we collect about you:
We may automatically collect information about your use of the Masabi Website, such as the number and duration of visits to the Masabi Website and details of which particular pages have been visited. We will anonymise this information so that it is not attributable to you (“Anonymised Information”).
We also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform as well as cookie, tracking pixel and beacon identification information (“Technical Information”). Please see our Cookies Policy for more information.
We use any collected Technical Information and Anonymised Information to analyse how the Masabi Website is functioning and how it is used by users, for insight purposes and to help us maintain and improve the Masabi Website on an ongoing basis.
Information we collect about you from other sources:
We may also obtain the following Personal Information about you from the following sources:
| Third Party Name | Categories of Data Collected |
| Hubspot Email AI |
Contact information
|
3. HOW AND WHY WE USE YOUR PERSONAL INFORMATION
In relation to your personal information that we process as a controller, data protection law requires us to have a valid reason to process it for each of the different purposes for which we use that information. The law refers to each reason as a ‘lawful basis’. The purposes for which we use your personal information and the lawful basis on which we rely to process it for each purpose is as follows:
Where you have provided CONSENT
We may use and process your personal information where you have consented for us to do so for the following purposes:
- to conduct analytics relating to your use of/interactions with the Masabi Website and whether you have opened or received our electronic communications (please see our Cookies Policy for more information).
You may withdraw your consent for us to use your information in any of these ways at any time. Please see paragraph 11 (Your Rights) for further details.
Where necessary to comply with our LEGAL OBLIGATIONS
We will use your personal information to comply with our legal obligations:
- to keep a record relating to the exercise of any of your rights relating to our processing of your personal information;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- to anonymise or delete your personal information when it is no longer required for the purposes described in this Privacy Policy;
- to comply with court orders or other notices where failure to do so would result in us breaking the law; and
- to handle and resolve any complaints we receive relating to our processing of your personal information as described in this Privacy Policy.
Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:
Processing necessary for us to promote our business and measure the reach and effectiveness of our campaigns
- to contact you with marketing information by email, post or by phone (if you are not registered with the Telephone Preference Service (including the Corporate Telephone Preference Service));
- for analysis and insight conducted to inform our marketing and business strategies, and to enhance your user experience;
- to identify and record when you have received, opened or engaged with the Masabi Website and/or our electronic communications (please see our Cookies Policy for more information).
Processing necessary for us to respond to changing market conditions and the needs of our users
- to analyse, evaluate and improve the Masabi Website and/or our products so that your visit and use of the Masabi Website and/or products are more useful (we will generally use data amalgamated from many people so that it does not identify you personally);
- to undertake market analysis and research (including contacting you with customer surveys) so that we can better understand your use of the Masabi Website and our products;
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
- to process payments made by you (on behalf of your employer) to us;
- to administer the Masabi Website and our products, and for internal operations, including troubleshooting, testing, statistical purposes;
- for the prevention of fraud and other criminal activities;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- for the purposes of corporate restructure or reorganisation or sale of our business or assets;
- for efficiency, accuracy or other improvements of our databases and systems, for example, by combining systems or consolidating records we hold about you;
- to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
- to inform you of updates to our terms and conditions and policies; and
- for other general administration including managing any reports you make, your queries, complaints, or claims, and to send service messages to you.
Where necessary for us to carry out PRE-CONTRACT STEPS you have requested or for the performance of our CONTRACT
We will use your personal information where this is necessary for us to perform our contract with you or to carry out any pre-contract steps you’ve asked us to so that you can enter into that contract, for the following purposes:
- respond to your request for a product demonstration; and
- to respond to your customer service requests and enquiries.
4. DISCLOSURE OF YOUR PERSONAL INFORMATION BY US
We may disclose your information to our third party service providers, agents and subcontractors (“Suppliers”) for the purposes set out above. Our Suppliers can be categorised as follows:
| Recipient / relationship to us | Industry sector (& sub-sector) |
| Group companies | Transport (Technology) |
| Advertising, PR, digital and creative agencies | Media (Advertising & PR) |
| Commercial partners | Transport (Technology) |
| Cloud software system providers, including database, email and document management providers | IT (Cloud Services) |
| Facilities and technology service providers including scanning and data destruction providers | IT (Data Management) |
| Insurers and insurance brokers | Insurance (Underwriting & Broking) |
| Legal, security and other professional advisers and consultants | Professional Services (Legal & Accounting) |
| Market and customer research providers | Media (Market Research) |
| Social media platforms (see paragraph 10) | Media (Social Media) |
| Website and data analytics platform providers | IT (Data Analytics) |
| Website and app developers | IT (Software Development) |
| Website hosting services providers | IT (Hosting) |
When sending your information to third parties, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
When we share your personal information with any third parties that are controllers of that information, they may disclose or transfer it to other organisations in accordance with their data protection policies. This does not affect any of your data subject rights as detailed below. In particular, where you ask us to rectify, erase or restrict the processing of your information, we take reasonable steps to pass this request on to any such third parties with whom we have shared your personal information.
We may disclose your personal information to other third parties as follows:
- any third party who is restructuring, selling or acquiring some or all of our business or assets or otherwise in the event of a merger, re-organisation or similar event; and
- if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police, tribunals, regulators, the government or related agencies.
5. WHERE WE STORE YOUR PERSONAL INFORMATION
Your personal information may be transferred to or stored by a third party located in another country, including countries that may have privacy protections less stringent than in the UK. In accordance with applicable law, we implement measures, such as standard contractual clauses or declarations by regulators or governments (e.g. adequacy decisions) to ensure that any transferred personal information remains protected and secure.
Please contact us using the details at the end of this privacy policy for more information about the protections that we have put in place and to obtain a copy of the relevant documents.
6. THE PERIOD FOR WHICH WE KEEP YOUR PERSONAL INFORMATION
If we collect your personal information, the length of time for which we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under paragraph 3 (How and why we use your personal information) above. The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see paragraph 11 (Your Rights) below); or
- you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see paragraph 11 (Your Rights) below).
7. SECURITY AND LINKS TO OTHER SITES
We employ security measures to protect the personal information you provide to us, to prevent access by unauthorised persons and unlawful processing, accidental loss, destruction and damage. When we have provided (or you have chosen) a password allowing you access to certain parts of the Masabi Website, you are responsible for safeguarding it and keeping it confidential and you promise not to allow it to be used by third parties.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do everything possible to protect your personal information, we cannot guarantee the security of any personal information during its transmission to us online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we are at fault.
If you are using a computer or terminal in a public location, we recommend that you always log out and close the website browser when you complete an online session for your security. In addition, we recommend that you take the following security measures to enhance your online safety: When creating a password, we recommend use at least 8 character with a combination of letters and numbers. We recommend you frequently change your password. Keep your passwords private. Remember, anyone you knows your password may access your account. Avoid using the same password for multiple online accounts. We will never ask you to confirm any account or credit card details via email. If you receive an email claiming to be from masabi.com asking you to do so, please ignore it and do not respond.
The Masabi Website may contain links to other websites run by other organisations which we do not control. This Privacy Policy does not apply to those other websites‚ so we encourage you to read their privacy policies. We are not responsible for the privacy policies and practices of other websites (even if you access them using links that we provide) and we provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.
In addition, if you linked to the Masabi Website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
8. COOKIES
‘Cookies’ are small pieces of information sent to your computer or device and stored on its hard drive to allow the Masabi Website to recognise you when you visit it. The Masabi Website uses cookies to obtain an overall view of visitor habits and visitor and user volumes to the Masabi Website.
If you are using the Masabi Website, it is possible to switch off cookies by setting your browser preferences. For more information on how we use cookies and how to switch them off on your device, please visit our Cookies Policy.
9. AUTOMATED DECISION MAKING
We do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this Privacy Policy and inform you if this position changes.
10. SOCIAL MEDIA PLATFORMS
We use a number of different social media platforms to communicate with you and to promote products and services. We process your personal information using these platforms in a variety of ways, as follows:
Pages. We use your personal information when you post content or otherwise interact with us on our official pages on Facebook, LinkedIn, Instagram, Twitter and other social media platforms. We also use the Page Insights service for Facebook and Instagram to view statistical information and reports regarding your interactions with the pages we administer on those platforms and their content. Where those interactions are recorded and form part of the information we access through these Page Insights services, we and the relevant platform are joint controllers of the processing necessary to provide that service to us.
Cookies. We use cookies and similar technologies in our Website to collect and send information to Facebook about actions you take on our website and applications. In particular:
- Facebook uses this information to provide services to us and also for further processing for its own business purposes. We and Facebook are joint controllers of the processing involved in collecting and sending your personal information to Facebook using cookies and similar technologies as each of us has a business interest in Facebook receiving this information. You can find out more about these technologies by visiting our Cookies Policy. The services we receive from Facebook that use this information are delivered to us through Facebook’s Business Tools, which include Facebook Pixel, Facebook Social Plugins and Website Custom Audiences. These tools allow us to target advertising to you within Facebook’s social media platform by creating audiences based on your actions on our Website and applications and allow Facebook to improve and optimise the targeting and delivery of our advertising campaigns for us.
Our relationship with Facebook. As we are joint controllers with these platforms for certain processing, we and each platform have:
- entered into agreements in which we have agreed each of our data protection responsibilities for the processing of your personal information described above;
- agreed that we are responsible for providing to you the information in this privacy notice about our relationship with each platform; and
- agreed that each platform is responsible for responding to you when you exercise your rights under data protection law in relation to that platform’s processing of your personal information as a joint controller.
Facebook also processes, as our processor, personal information that we submit for the purposes of matching, online targeting, measurement, reporting and analytics purposes. These services include the processing these platforms carry out when they display our advertisements to you in your news feed at our request after matching contact details for you that we have uploaded to them. These advertisements may include forms through which we collect contact information you give to us.
Further information. The Facebook company that is a joint controller of your personal information is Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. For further information regarding these platforms and their use of your personal information, please see:
- Facebook’s Controller Addendum for Page Insightsand Controller Addendum for Business Tools which include information regarding how our and those platforms’ responsibilities to you are allocated as controllers of your personal information;
- Facebook’s Data Policy at https://www.facebook.com/about/privacyand LinkedIn’s Privacy Policy at https://www.linkedin.com/legal/privacy-policy which include details of the legal reasons (known as ‘lawful bases’) on which each platform relies to process your personal information, together with details regarding your data protection rights; and
- Facebook’s help pagesregarding its Page Insights and Business Tools and its terms and conditions relating to those tools.
11. YOUR RIGHTS
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 1 calendar month from either:
- the date that we have confirmed your identity; or
- where we do not need to do this because we already have this information, from the date we received your request.
You have the following rights, some of which may only apply in certain circumstances:
| Your Rights | Further Information |
| To have your information corrected if it is inaccurate and to have incomplete personal information completed | If you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us using any of the details described at the end of this Privacy Policy. |
| To object to processing of your personal information | Where we rely on our legitimate interests as the lawful basis for processing your personal information for particular purposes, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this Privacy Policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data. |
| To withdraw your consent to processing your personal information | Where we rely on your consent as the lawful basis for processing your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this Privacy Policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful. |
| To restrict processing of your personal information | You may ask us to restrict the processing of your personal information in the following situations:● where you believe it is unlawful for us to do so; or● you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.
In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings. |
| To have your personal information erased | In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this Privacy Policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request. |
| To request access to your personal information and how we process it | You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this Privacy Policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information. |
| To electronically move, copy or destroy your personal information in a standard, machine-readable form | Where we rely on your consent as the lawful basis for processing your personal information or need to process it in connection with a contract in place directly with you, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information. |
| Rights relating to automated decision making, including profiling | You may also contest a decision made about you based purely on automated processing by contacting us using the information at the bottom of this Privacy Policy. |
| To complain to a data protection regulator | You have the right to complain to a data protection regulation (which in the UK is the Information Commissioner’s Office (ICO)) if you are concerned about the way we have processed your personal information. Please visit the for further details. |
12. CHANGES TO THIS PRIVACY POLICY
We may review this Privacy Policy from time to time and any changes will be notified to you by posting an updated version on the Masabi Website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on the Masabi Website, whichever is the earlier. We recommend you regularly check for changes and review this Privacy Policy whenever you visit or use the Masabi Website. If you do not agree with any aspect of the updated Privacy Policy you must immediately notify us and cease using our services.
13. CONTACT US
Please direct any queries about this Privacy Policy or about the way we process your personal information to our Privacy Manager using our contact details below.
If you wish to write to us, please write to Masabi Limited, 100 Avebury Boulevard, Milton Keynes, MK9 1FH, United Kingdom.
Our email address for data protection queries is privacy@masabi.com alternatively you can contact us via the Masabi Website.
Please see our Terms of Use for legal information about Masabi Limited.
May 2023