Megger Group Privacy Notice (2024)

Introduction
Welcome to Megger Group's privacy notice
Megger respects your privacy and is committed to protecting your personal information. This policy will inform you as to how we look after and use your personal information when you visit our website (regardless of where you visit it from) or otherwise interact with our organisation. This policy also tells you about your privacy rights and how the law protects you. This policy should be read in conjunction with our Cookie Policy and our Website Terms of Use.
This policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary (at the end of this policy) to understand the meaning of some of the terms used in this policy. 

1. Important information and who we are
2. The personal information we collect about you
3. How your personal information is collected
4. How we use your personal information
5. Disclosures of your personal information
6. Data location and international transfers
7. Data security
8. Data retention
9. Your legal rights
10. How to complain
11. Glossary

1. Important information and who we are 

Purpose of this privacy notice

This policy aims to give you information on how the Megger group of companies (the “Megger Group”) collects and processes your personal information, whether it is collected in person, via telephone, post, emails, texts or via your use of our websites, including any information you may provide via our websites, when you sign up to our newsletter, purchase a product or service or take part in a competition.
Our websites are not intended for children, and we do not knowingly collect information relating to children.
It is important that you read this policy together with any other data privacy, data use and data retention notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information. This policy supplements such other notices and is not intended to override them.
 

Responsible organization 

The Megger Group is made up of different legal entities. This policy is issued on behalf of the Megger Group, so when we mention "Megger", "we", "us" or "our" in this policy, we are referring to the relevant company in the Megger Group responsible for processing your personal information. We will let you know which entity will be the responsible organization for your personal information when you purchase a product or service with us.
This policy is issued by and on behalf of the board of directors of Megger Group Limited (the “Board”). No deviations may be made from it without written Board approval.
Megger Group Limited (details set out below) is the responsible organisation for our websites.
We have a Megger Group data privacy function responsible for answering questions relating to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact us using the details set out below.
 

Our full details are:
Full name of legal entity:  Megger Group Limited
Email address:  [email protected]
Postal address:  Archcliffe Road, Dover, Kent, CT17 9EN United Kingdom
 

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Megger Group Limited regularly reviews and may update this policy from time to time. Any changes to this policy will be reflected in the latest available version of this policy on our websites. We encourage you to view the latest version of this policy when accessing any of our services to stay informed about the latest handling processes and ways you can protect your privacy. 
 

Third-party links

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party platforms and are not responsible for their privacy practices. When you leave our website, we encourage you to read the privacy notice of every platform you visit.
 

2.    The personal information we collect about you 

In this policy, when we refer to “personal information”, we mean any information that can be used to identify an individual. This information is sometimes referred to using different terminology in different jurisdictions and is typically protected by law. By way of examples, personal information may be referred to as “personal data” (in the United Kingdom and the European Economic Area), “personally identifiable information” (in the United States of America) and simply as “personal information” (in Canada and Australia).
 

We may collect, use, store and transfer different kinds of personal information about you, including but not limited to the information which we have grouped together as follows: 

• Identity information, such as first name, maiden name, last name, username or similar identifier, date of birth, marital status, title, academic title, gender and LinkedIn profile. 
• Recorded information, such as photographs, video recordings, call recordings or CCTV recordings and written records of meetings and decision-making.
• Contact information, including but not limited to billing address, delivery address, email address and telephone numbers. 
• Financial information, such as bank account and payment card details and results of credit searches. 
• Transaction information, such as details about payments to and from you and other details of products and services you have purchased from us. 
• Technical information, including internet protocol (IP) address, your login information, 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 information, such as username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.   
• Usage information, such as information about how you use our website, products and services.  
• Marketing and communications information, such as your interactions, your communication preferences and subscription preferences in receiving marketing from us and our third parties.
• Information relating to any compliments, product reviews or complaints made by you.
   

We also collect, use and share aggregated data such as statistical or demographic information. Aggregated data may be derived from your personal information but is not considered personal information in law as this information 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 information so that it can directly or indirectly identify you, we treat the combined information as personal information, which will only then be processed in accordance with this policy. 
Other than financial information, we do not routinely collect any types of personal information that are considered to be sensitive or special category personal information in any jurisdictions, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric information, nor do we collect any information about criminal convictions and offences. We may, however, collect limited health-related information, such as dietary requirements or allergies, when voluntarily provided by you in the context of event participation (e.g., onsite seminars or lunches). This information is used solely for the purposes of accommodating your needs during such events and is not stored in any of our systems beyond the conclusion of the relevant event. We ensure this information is handled with the highest degree of confidentiality and in compliance with applicable data protection laws.
Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that information 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 with goods or services). In this case, we may have to cancel a product or service you have with us, but we will typically notify you if this is the case at the time, where reasonably possible.
 

3.    How your personal information is collected

Personal information is collected from several sources, including but not limited to direct correspondence with our customers, interaction with our websites, sales and marketing events, seminars, webinars, credit referencing agencies, debt collection agencies, CCTV footage, publicly available sources and data processing service partners (where they have obtained consent to disclose personal information to us).
 

We use different methods to collect information from and about you including, but not limited to, the following.
 

Direct interactions. You may give us your identity, contact and financial information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:
•    apply for our products or services;
•    create an account on our website;
•    subscribe to our news or other publications;
•    request marketing to be sent to you;
•    enter a competition, contest, promotion or survey; or
•    give us some feedback. 
 

Automated technologies or interactions. As you interact with our website, we may automatically collect technical information about your equipment, browsing actions and patterns. We collect this technical information by using cookies, server logs and other similar technologies. We may also receive technical information about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details on cookies.
Third parties or publicly available sources. We may receive personal information about you from various third parties (with your consent) and public sources as set out below:

• Technical data from the following parties:
•   -   analytics providers such as Google; 
•   -  advertising networks; and 
•   -  search information providers. 
• Contact, financial and transaction information from providers of technical, payment and delivery services. 
• Identity and contact information from referencing companies and information brokers or aggregators. 
• Identity and contact information from publicly availably sources such as telephone directories or professional or business directories.
   

4.    How we use your personal information 

We will only use your personal information with your consent or as otherwise permitted under applicable law. Most commonly, we will use your personal information in the following circumstances: 
•    where we need to perform the contract we are about to enter into or have entered into with you;
•    for any purpose for which you have consented;
•    where it is necessary for our legitimate interests, as permitted by applicable law; 
•    to enforce our website terms and conditions, our terms and conditions of sale or any other legal rights;
•    where we need to comply with a legal or regulatory obligation; or
•    to send direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us on [email protected] 

Purposes for which we will use your personal information 

We have set out below, in a table format, a description of the ways we plan to use your personal information, and the reasons for such use.
Please contact us for any questions regarding the use of your personal information on the following email address: [email protected]

Marketing

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. To that end, we have established the following personal information control mechanisms.

Promotional offers from us. We may use your identity, contact, technical, usage and profile information 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 products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving marketing. 

Third-party marketing. We will require your express opt-in consent before we share your personal information with any company outside the Megger Group for marketing purposes.

Opting out. You can ask us to stop sending you marketing messages at any time by contacting us on [email protected] or by logging into your account on our website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, you may still receive electronic messages from us related to a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies. You can set your browser to refuse all or some browser cookies, or to alert you when 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. Please refer to our Cookie Policy for more details on our use of targeted advertising. 
 

Change of purpose. We will only use your personal information for the purposes for which you consented or as otherwise permitted under applicable law. If we need to use your personal information for an additional purpose, we will obtain your consent, where required by applicable law. 
Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by applicable law.
 

5.    Disclosures of your personal information 

We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above:
    

• Companies in the Megger Group  that are based globally and process your personal information whilst providing IT and system administration services and undertaking management, service provision and reporting activities.
• Microsoft, as the provider of our email servers, cloud-based document management systems and office software.
• SAP, as the provider of our cloud-based customer relationship management databases.
• Other Saas and Service providers who provide software, IT and system administration services to the Megger Group (including Acquia and Kenitco).
• Third party suppliers who may supply goods and/or services to the Megger Group (which may be incorporated or form part of the products or services we supply to you).
• Professional advisers acting as responsible organisations or service providers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and other authorities who may require reporting of processing activities in certain circumstances.
• Specific third parties such as credit reference agencies, fraud prevention agencies, debt collection agencies or other parties to whom we may be required by law to disclose your personal information.
• Emergency services.
• 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. If a change of this type occurs in our business, then any new owners or any new incorporation of our business may use your personal information in the same way as set out in this policy.
   

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and we only permit them to process your personal information for specified purposes and in accordance with our instructions.
 

6.    Data location and international transfers 

We will typically store your personal information in a secure data centre in the United Kingdom, the European Economic Area or the United States of America (our “Core Jurisdictions”).

We may share your personal information within the Megger Group and with certain third parties in accordance with this policy in order to provide you with our goods and services and for other purposes, as set out in the table in paragraph 4 above.

Your personal information may be accessible by our authorised personnel and subcontractors from outside your jurisdiction to provide you with our goods and services and for other purposes as set out in the table in paragraph 4 above.
 

We will ensure that any access to your personal information by Megger Group personnel or any affiliates or third parties outside your jurisdiction is subject to all contractual, procedural and technological protections required by law and which are applicable to your personal information.
 

Whenever we transfer your personal information outside your jurisdiction, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information.
• Where your personal information is transferred outside those jurisdictions, we will ensure that all the protections required by law are in place.
• Where your personal information is processed by our service providers, we may use specific contracts approved for use by the relevant authorities in your jurisdiction (such as the Information Commissioner’s Office in the United Kingdom) which give personal information at least the same protection it has in your jurisdiction.

Your personal information may be subject to the laws of the jurisdiction where it is transferred and may be accessible without notice to you by the courts, law enforcement and national security authorities of that jurisdiction.  Please contact us if you want further information about our policies and practices with respect to the processing of your personal information outside your jurisdiction.
 

7.    Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected and confirmed personal information breach and we will notify you and any applicable regulator of a breach where we are legally required to do so.

Business alerts and SMS messages

Some Megger Group products offer a service that sends alert information to a designated telephone number. It is our policy to protect the confidentiality of such telephone numbers (where we collect them) and any related information sent via such alerts.
 

8.    Data retention 

How long will you use my personal information for? 

In most cases your information will be held for no longer than seven (7) years from the last point of contact. However, it is our policy only to store information for as long as reasonably necessary for us to comply with our legal obligations and fulfil the purpose(s) for which it was collected.
 

Subject to applicable law, personal information may be kept longer than seven (7) years for reasons such as crime prevention, detection or repression, archiving purposes in the public interest, scientific and historical research purposes, for tax purposes or for statistical analysis. 
 

When information is no longer required by the Megger Group and does not have archival value it will be securely destroyed.
 

To determine the appropriate retention period, we take into consideration, without limitation, the purpose for collecting and processing the information, the amount of information, the sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of the information, relevant legal requirements and whether we can achieve the intended purpose through other means.

In certain circumstances we may anonymise your personal information (so that it can no longer be directly or indirectly associated with you) for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes in which case we may use this information indefinitely without further notice to you.

Personal information obtained via third party partners will be kept for up to 12 months. If there have not been any interaction, correspondence or transactions with the relevant information subject at that time, such personal information will be removed from our systems.

Deletion policy

When personal information has reached the end of the relevant retention period, the personal information will usually be reviewed to ensure that it is no longer necessary for the personal information to be retained. For some personal information, however, Megger has an automated retention schedule, and information subject to an automatic action to destroy may be disposed of without review. 
 

Information may be retained beyond the applicable retention period in certain circumstances, including but not limited to the following purposes:

1.    to fulfil statutory legal or regulatory requirements;
2.    to adhere to a request by you as the owner of your personal information; or
3.    if the information is required to fulfil purposes of public interest/ archival interest.
 

When information is set for permanent deletion, digital and paper documents will be destroyed simultaneously. Digital documents will be permanently deleted and not overwritten; this will include any back-ups to the extent technologically practicable. Paper records will be placed in confidential waste bins and securely destroyed.
 

9.    Your legal rights 

In certain circumstances under privacy laws, and dependent on the jurisdiction in which you are resident, you may have individual rights surrounding your personal information, which may include those summarised below. To access further information regarding your rights you can refer to the data protection or personal information regulator in your country of residence. 
 

You may have the right to:

Request access to your personal information (which may be referred to as a “Subject Access Request” or “Access Request”). Subject to certain legal exceptions, this enables you to receive a copy of the personal information we hold about you and to be informed of its use and disclosure. 
 

Request correction of the personal information that we hold about you. Subject to certain legal exceptions, this enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us. 
 

Request to erase your personal information (which may be referred to as a “Request for Erasure” or a “Request for Deletion”). This enables you to ask us to delete personal information where the information is no longer required for the purpose(s) for which it was collected or is obsolete. You may also have the right to ask us to delete or remove your personal information where the information was not collected or processed in a lawful manner. Note, however, that we may not always be able to comply with your request for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
 

Object to processing. You may have the right to object to the processing of your personal information if we are relying on a legitimate interest (or those of a third party) and you believe our processing of your personal information impacts your fundamental rights and freedoms. This includes objecting to the use of your information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to continue processing your information that override your rights and freedoms.
 

Request restriction of processing. You can ask us to suspend the processing of your personal information in certain circumstances, for example:

• if you want us to verify the accuracy of the personal information;
• if our use of the personal information is unlawful, but you do not want it erased;
• if you need us to retain the personal information even if we no longer require it, for example, to establish, exercise, or defend legal claims; or
• if you have objected to our use of your personal information, but we need to verify whether we have overriding legitimate grounds to continue using it.
   

Request the transfer of your personal information to an authorised person. Where required under applicable law, we will provide your personal information to an authorised person in a structured and commonly used technological format. Note that this right normally only applies to computerised personal information that was collected directly from you.
 

Withdraw consent at any time (where we are relying on consent to process your personal information). 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 products or 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 (or any other rights that may exist in your country of residence), please contact us at the above address marked for the attention of the “Megger Personal Data Function” or email us on [email protected] .
 

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of your 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, where permitted by law.
 

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.
 

Time limit to respond

We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you reasonably updated.
 

10.    How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us using the contact details at the top of this policy.
 

If you remain unhappy with how we have used your personal information after raising a complaint with us, you can also complain to your local data protection authority.
 

11.    Glossary 

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 information for our legitimate interests. We do not use your personal information 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.
 

Performance of a contract means processing your information where it is necessary for the performance of a contract to which you or your affiliates are a party or to take steps at your request before entering into such a contract.