1.0 Our core beliefs regarding user privacy and data protection
- User privacy and data protection are human rights
- We have a duty of care to the people within our data
- Data is a liability, it should only be collected and processed when absolutely necessary
- We loathe spam as much as you do!
- We will never sell, rent or otherwise distribute or make public your personal information
- We will never disclose your payment details to third parties as they are NOT stored on any of our servers.
2.0 Relevant legislation
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
- Australian Privacy Act 1988 (APA)
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well.
3.0 Personal information that this website collects and why we collect it
This website collects and uses personal information for the following reasons:
3.1 Customer Transactions
We may process information relating to purchases of goods that you enter into with us through our website. The transaction data may include your contact details, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website.
3.2 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 6.0 below).
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
In addition to Google Analytics, this website may collect* information (already held in the public domain) attributed to the IP address of the computer or device that is being used to access it. The information is supplied to us from Whoisvisiting.com. Whoisvisiting.com is a service offered by Whoisdata Limited. The Whoisvisiting system does not use your IP address to identify you, the individual, in any way. No cookies are used by the Whoisvisiting system.
* The Whoisvisiting system will only lookup information when a static IP address is being used. Differences between a static and dynamic IP address.
More information about how Whoisvisiting uses IP addresses.
3.3 Our news blog
Should you choose to add a comment to any posts that we have published on our news blog, the name and email address you enter with your comment will be saved to this website’s database, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third party data processors detailed below. Only your name will be shown on the public-facing news item.
Your comment and it’s associated personal data will remain on this site until we see fit to either 1.) remove the comment or 2.) remove the blog post. Should you wish to have the comment and it’s associated personal data deleted, please contact us here using the email address that you commented with.
If you are under 16 years of age you MUST obtain parental consent before posting a comment on our blog.
NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog post comments that you submit on this website.
3.4 Contact forms and email links
Should you choose to contact us using the contact form on our Contact us page or an email link, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in section 6.0. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our own SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. However, not all mail servers are secured in such a way. Therefore, we would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information within an email.
3.5 Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third party data processor (see section 6.0 below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.
Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via our Contact Us form. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the MailChimp database, you will receive periodic (one every few months) newsletter-style emails from us.
4.0 How we store your personal information
As detailed in section 3.2 above, if you submit a comment to a blog post published on this website some personal information will be stored within this website’s database. If you place an order on our website, your personal information will also be stored within this website’s database. This data (when at rest) is currently stored in a protected, but identifiable fashion; a limitation of the framework this website is built on. In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.
When the data is in motion it is encrypted via Secure Sockets Layer
5.0 About this website’s server
This website is hosted within a UK data centre located just outside London.
Some of the data centre’s more notable security features are as follows:
- 3m rota-spike security fence and perimeter anti ram barriers
- Blast proof anti-intruder shielded external windows and doors
- Proximity access locks on all external and internal doors
- Biometric access control
- Server cabinets have locked doors (no open racks)
- Perimeter and internal IP CCTV system monitored 24×7
- 24/7 datacentre security
- Only authorised security cleared staff are allowed into the facility
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
6.0 Our third party data processors
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. All of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.
6.1 Payment Service Providers
MEkey ICE ID will never disclose your payment details to third parties as they are NOT stored on any of our servers.
All financial transactions relating to our website are handled by our payment services provider, PayPal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments. You can find information about the PayPals privacy policies and practices here.
7.0 Data Breaches
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
8.0 Data Controller
The data controller of this website is: MEkey ICE ID
PO Box 4491
9.0 Your Data
Everyone has a right to know who holds what information about them.
You may request details of personal information which we hold about you under GDPR. If you would like a copy of the information held on you please contact us here.
If you believe that any information we are holding on you is incorrect or incomplete, please email us as soon as possible. We will promptly correct any information found to be incorrect.
If you want your personal data erased from our systems, please get in touch and it will be carried out with undue delay.
10.1 Change Log
10/05/18 – version 2.01
- added links to explanation pages
10/05/18 – version 2
- Full update for GDPR compliance
Cookies are small pieces of information that are stored by your browser on your computer hard drive.
- To ensure that items are placed into your Shopping Basket and orders are processed correctly.
- To identify you as a user as you travel around our site.
- To provide site usage information, which together with purchase information, will further help us improve and develop the products and services we offer.
No recognisable personal information is stored in the cookie that can link it back to an individual – usually a random string of numbers and letters.
You will need to ensure your cookies are enabled which will allow you to register your details and to purchase from our site.