Maximillian Workflows

Introduction

Welcome to Maximillian Workflows Privacy Policy.

Maximillian Workflows respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Maximillian Workflows provides a platform for the execution of workflow processes on behalf of our Clients. Maximillian collects data from our Clients' Customers on behalf of our Clients for use in our Clients' business processes for the purposes of conducting business activity. The data so collected is primarily owned and governed by our Clients. We however provide facilities and tooling necessary for our Clients to properly maintain their data on our platform in accordance with the law, our Clients privacy policies and this document.

In all cases where our Clients present and collect data from users using their own trademarks (as in when using a Client's website), our Clients dictate and define how personal data is collected, for what purpose it is used and for how long the data will be retained for; except for the purposes of user authentication on the platform. Our Clients must maintain specific privacy policies related to their business practices. Our Clients Privacy Policies shall always be as restrictive and sufficient as to remain within bounds of this privacy document and those required by law. In the first instance, our Clients should be contacted to resolve any privacy issues. In the event of our Clients' failing to resolve any issues, we can step in and address the same.

For the purposes of this document, "Customers" shall refer to users of the Maximillian Workflows branded sites, including the Admin Console, and provisioning applications, and users of the registry and authentication mechanisms we provide to our clients.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Who are we?

Maximillian Workflows is a trading name for the service owned and operated by Malbec Limited. We are registered in the UK in England and Wales under company number 07359179, with our registered office located at W8a Knoll Business Centre, 325-327 Old Shoreham Road, Hove, England, BN3 7GS.

If you need to reach us you can reach us at support@maximillian-workflows.com

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.

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).

Identity Data includes first name, last name, username, title and date of birth.
Contact Data includes address, email address and telephone numbers.
Technical Data includes internet protocol (IP) 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 our websites.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

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 (for example, to provide you services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
1. apply for our services;
2. create an account on our websites;
3. subscribe to our service or publications;
4. register and use our Clients' websites where we are hosting them on our platform;
5. request marketing to be sent to you;
6. enter a competition, promotion or survey; or
7. give us some feedback.
Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details. This Privacy Policy should be read in conjunction with our Cookie Policy.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
1. analytics providers such as Google based outside the EU;
2. advertising networks ; and
3. search information providers.
4. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
5. Identity and Contact Data from data brokers or aggregators.
6. Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

How we use 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 and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to analysing results of surveys or sending third party marketing communications to you via email or text message. However, occasionally we may need to share your data with our employees or partners outside the UK/EEA in performance of our contractual obligations to you, our general legal obligations or for our legitimate purposes, including financing. By consenting to use our services, you consent to the transfer of your data to such individuals or companies for a limited purpose in performance of our contractual obligations or in pursuit of our legitimate interests.

You have the right to withdraw consent to the data transfer outside the UK and the EEA at any time by sending us an email at support@maximillian-workflows.com. Please, note that if you withdraw your consent to the transfer of your data outside the UK/EEA we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

Purposes for which we use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Identity Contact	Performance of a contract with you
To process your order and deliver services to you including: Manage payments, fees and charges Collect and recover money owed to us	Identity Contact Financial Transaction	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our services) consent (where results of a survey are analysed outside the UK/EEA)
To enable you to partake in a prize draw, competition or complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business) Consent (where results of a survey are analysed outside the UK/EEA)
To manage, administer and protect our business (including legal and accounting support, investments and leverage) and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	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) Necessary to comply with a legal obligation Consent (where we use providers outside UK/EEA or seek to raise funds by investments or lending)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our services, including enhancing existing services and developing new features, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy) Consent (where our IT personnel is based outside UK/EEA)
To make suggestions and recommendations to you about goods or services that may be of interest to you, including goods and services of our partners	Identity Contact Technical Usage Profile	Necessary for our legitimate interests (to develop our services and grow our business) Consent (where we make recommendations concerning goods and services of our partners)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

We will secure your express opt-in consent before we share your personal data with any company outside Malbec Limited for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by sending us an email on support@maximillian-workflows.com or logging into our maximillian-workflows.com website and checking or unchecking relevant boxes to adjust your marketing preferences. Alternatively, you can adjust your marketing preferences by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

Cookies

By consenting to use our websites, you consent to storing cookies on your device. You can set your browser to refuse all or some browser cookies, or to alert you when our websites set or access cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly. For more information about the cookies we use, please see the Cookie Policy.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

Disclosures of your personal data

Authorities as mandated by the law.
Clients where you have registered your details using our platform and who own and possess your data, that we hold on their behalf.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

At no point will we ever share personal data you have registered under a Client account with another Client. If you happen to register with multiple Clients on our platform, then you are for all purposes multiple separate identities, and need to process any related privacy issues separately.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

International Transfers

We may occasionally need to share your data with our group companies, employees, partners or providers, such as accountants or lenders, who are based outside the EEA, as specified in paragraph 4 above. This will involve transferring your data outside the European Economic Area (EEA) and the UK where existing laws do not provide the same level of protection for the security of your personal data. For example, your consent to the transfer of your personal data to the third parties may be implied whenever you provide your data, which makes your personal data vulnerable to misuse. By consenting to use our Services, you consent to the transfer of your data to such individuals or companies for a limited purpose in performance of our contractual obligations or in pursuit of our legitimate interests. However, we require all involved parties to respect the security of your personal data and to treat it in accordance with principles of confidentiality.

You have the right to withdraw consent to the data transfer outside the UK and the EEA at any time by following sending us an email on support@maximillian-workflows.com. Please, note that if you withdraw your consent to the transfer of your data outside the UK/EEA, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

Please, note that our surveys are currently processed outside the European Economic Area (EEA) and the UK. We will secure your express opt-in consent before you take any of our surveys.

Please, contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, 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.

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.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and legal purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymize 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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

Maximillian Workflows provides a platform for our Clients to collect data from their Customers. We encourage you, as a Customer, to make every effort to contact the Client before reverting to us, as our Clients understand you and your data and are in a much greater position to address and mitigate any concerns you may have. Infact we make every effort not to interpret the data we hold on the Clients' behalf, in accord with the principle that your private data is indeed private.

If you still wish to exercise any of the rights set out above, please contact us at support@maximillian-workflows.com.

Please also note that you, as a Customer, might be the Customer of potentially more than one of our Clients. In these circumstances you have one identity for each Client with which you are registered. If you wish to exercise any of your rights listed above, you must identify which identity belonging to which Client you wish to affect. We never share Customer data between Clients, and so will never reveal your other identities not specifically under the domain of a specific Client.

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 may refuse to comply with your request in these circumstances.

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). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may 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.