PRIVACY POLICY

Your personal data

Privacy Notice for customers, prospects, partners and suppliers

Last updated: May 25, 2018

Memeo cares about your privacy

Memeo Inc. (a division of UNICOM Global) and its international subsidiary and branches (referred to herein as Memeo) are committed to protecting the personal information that you provide to Memeo, in adherence to Data Protection Legislation (defined below) and best business practice.

This Privacy Notice describes Memeo’s practices in relation to the use of its websites, web portals and FTP servers (“Websites”) and the related products, applications and services offered by Memeo. This Privacy Notice sets out how Memeo uses and protects any personal data that you provide to Memeo, including personal data provided through its Websites.

Memeo provides software products and services to its customers and as a result may collect and process personal data about individuals (“Services”).

Memeo maintains the same practices with data that is collected off-line and this notice may be relied upon with respect to those methods of data collection and use.

Memeo may modify or update its Privacy Notice at any time without prior notice. You can check the “Last updated” date above to see when the notice was last changed.

How to contact us

If you have any questions regarding your personal data and how Memeo may use it, including any queries relating to this Privacy Notice, please contact us by email at compliance@unicomsi.com or by writing to the “Privacy and Risk Management Committee” at Memeo, 15535 San Fernando Mission Blvd, Mission Hills, CA 91345, United States.

It is important that the personal data Memeo holds about you is accurate and current. Please keep Memeo informed if your personal data changes during your relationship with Memeo.

Terminology used

Memeo’s data protection and privacy measures are governed by the (i) the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998 (“Data Protection Legislation").

For the purpose of Data Protection Legislation:

  1. where personal data is provided directly to Memeo through use of its Websites, email, or other means where Memeo is determining the way in which that personal data is processed, then Memeo will be a data controller of such information; and
  2. where Memeo is provided personal data in its capacity of providing Services to its customers, then Memeo will only process that personal data in accordance with the instructions of its customers and Memeo will therefore act as a data processor in respect of such personal data; Memeo’s customer will be the data controller of that personal data for that purpose.

Where Memeo acts as a data processor on behalf of its customers, Memeo will process that personal data on the instructions of the customer, who would have collected that personal data in accordance with that customer’s own privacy policy. The data subject should therefore check the customer’s own privacy policy, to ensure they understand how their personal data may be processed.

Information we collect

Personal data means any data or information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Memeo will only collect basic personal data about you, such as your name, email address, business type, work address, job title (“identity data”) and any product/solution interests that you have shared (“preferences data”) and information relating to your use of Memeo Websites (“usage data”). Unless otherwise agreed with you, this information will not include any special categories of personal information (often known as “sensitive personal data”).

When visiting a Memeo Website, information is captured using cookies. To find out more about Memeo’s use of website cookies, please visit our cookies policy.

Memeo uses different methods to collect personal data from and about you including through:

  • Direct interactions. You may give Memeo your contact information by filling in forms or by corresponding with Memeo by post, phone, email or otherwise. This includes personal data you provide when Memeo provides its Services; or
  • Third parties or publicly available sources. Memeo may receive personal data about you from various third parties and public sources such as:
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services including third party debt agencies; and
    • Identity and Contact Data from publicly available sources such as Companies House

If you fail to provide personal data

Where Memeo needs to collect personal data by law, or under the terms of a contract Memeo has with you (or our customer whom Memeo acts for) and you fail to provide that data when requested, Memeo may not be able to perform the contract it has or is trying to enter. In this case, Memeo may have to cancel the Services but it will notify you (or where appropriate, its customer) if this is the case at the time.

How we use information that we collect

Memeo will only use your personal data when the law allows it to, i.e. if Memeo has a legal basis for doing so, as outlined in this Privacy Notice or as notified to you at the time in which Memeo collects your personal data, and for the purposes for which it was collected for, unless Memeo reasonably considers that it needs to use it for another reason and that reason is compatible with the original purpose. If Memeo needs to use your personal data for an unrelated purpose, Memeo will notify you and will explain the legal basis which allows it to do this. Please note that Memeo may process your personal data without your knowledge or consent, where this is required or permitted by law.

Memeo will use your personal data to carry out its contractual obligations and, in addition, to keep you up-to-date with its products and services that you have expressed an interest in. Where Memeo act as the data controller for customer contact information, it has set out below in the table a description of all the ways it plans to use your personal data, and which of the legal bases Memeo relies on to do so. Memeo has also identified what its legitimate interests are, where appropriate.

Note that Memeo may process your personal data for more than one lawful grounds depending on the specific purpose for which Memeo is using your data. Please contact Memeo if you need details about the specific legal ground that it is relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you or the company that you are connected to as a new customer and verify your identity (where required) Identity / contact data Performance of a contract Consent (for use of special categories of data, if applicable)
To perform credit checks Identity / contact data Legitimate interests
To process and deliver the Services including:
(a) Manage accounts, payments, fees and charges
(b) Contacting you and corresponding about the Services
Identity / contact data Performance of a contract
Necessary for Memeo’s legitimate interests (to recover debts due to Memeo)
To respond to queries and enquiries Identity / contact data Legitimate interests
To undertake marketing to you Identity / contact / preferences data Legitimate interests

Where Memeo acts as a data processor of personal data on behalf of its customers, in accordance with Memeo’s customers’ instructions or in order to comply with a legal or regulatory obligation.

How your personal data may be shared

Where Memeo acts as the data controller for customer contact information, or where permitted by Memeo’s data controller customers, personal data processed by Memeo may be shared as follows:

  • With any member of the Memeo group of companies (as detailed above);
  • With permitted third party contractors of Memeo for the purposes of performing its Services;
  • Where Memeo is under a duty to disclose your personal data to comply with any legal obligation, or to enforce or apply Memeo’s terms and conditions and other agreements;
  • To protect the rights, property, or safety of Memeo, Memeo’s customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and for compliance with laws; and
  • With third parties to whom Memeo may choose to sell, transfer, or merge parts of its business or its assets. Alternatively, Memeo may seek to acquire other businesses or merge with them. If a change happens to Memeo’s business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

Memeo requires all third parties to respect the security of your personal data and to treat it in accordance with the law. Memeo does not allow its third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with Memeo’s instructions.

Memeo will not share your information for marketing purposes with third party companies outside of its group of companies.

You can choose to unsubscribe from Memeo marketing communications at any time using the unsubscribe option on any electronic communication sent from Memeo. You may continue to receive further communications where a contractual or legitimate interest exists.

Memeo may use third party companies when processing your personal information. If you would like to find out which third party processors are used by Memeo, please contact Memeo as outlined above.

How long we keep your information for

Where Memeo acts as a data controller, it will not keep your personal information longer than is necessary for the purpose in which it was provided, unless required by law, or for other legitimate reasons that need it to be retained for longer (for example, if necessary for any legal proceedings). Where Memeo acts as a data processor on behalf of its customers, Memeo will only hold on to personal data for the period notified to Memeo by the data controller customer, or for the period required for the purposes of satisfying any legal, accounting, regulatory or reporting requirements

Your rights

Under Data Protection Legislation, you have the following rights in certain circumstances:

  • The right to be informed – this is information on Memeo’s collection and use of your personal data.
  • The right of access – you have the right to be provided with copies of the personal data of you that Memeo is processing as well as confirmation of the processing Memeo is doing. You can do this by sending a “subject access request” to the contact details noted above for Memeo’s consideration.
  • The right to rectification – if you think the personal data that Memeo holds on you is wrong, you can inform Memeo and Memeo will fix it.
  • The right to erasure (also known as the right to be forgotten) – if you want Memeo to permanently delete the personal data it holds about you then you can ask Memeo to do so.
  • The right to restrict processing – if you do not like how Memeo is using your personal data then you can let Memeo know and Memeo will stop processing it in that way.
  • The right to data portability – if you want Memeo to pass on your personal data to someone else then please let Memeo know. This transfer should not affect the integrity or otherwise damage your personal data.
  • The right to withdraw your consent – you can withdraw your consent for Memeo to process your personal data (if Memeo has relied on your consent to process your personal data) at any time by contacting Memeo. If Memeo has relied only on your consent as the basis to process your personal data then Memeo will stop processing your personal data at the point you withdraw your consent. Please note that if Memeo can also rely on other bases to process your personal data aside from consent then Memeo may do so even if you have withdrawn your consent.
  • Rights in relation to automated decision making and profiling – if Memeo use either automated decision making or profiling then you have a right to know. Also, Memeo needs your consent if either of these are used to make a decision that affects you. As with all consent, you can withdraw it at any time.

To exercise any of the above rights please email your request to: compliance@unicomsi.com

Where you exercise your right to erasure or where information is deleted in accordance with Memeo’s retention policy, please note that after the deletion of your personal data, it cannot be recovered, so if you require a copy of this personal data, please request this during the period Memeo retains the data.

Where you exercise your right to request access to the information Memeo processes about you, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, Memeo may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Alternatively, Memeo may refuse to comply with your request in these circumstances.

Memeo will try to respond to all legitimate access requests within one month. Occasionally it may take longer than a month if your request is particularly complex or you have made a number of requests. In this case, Memeo will notify you and keep you updated.

Children

Memeo Websites are not intended for children and Memeo will not knowingly collect any personal data from persons under the age of 18 and will immediately delete any such data subsequently so determined.

How to raise a concern about the use of your personal information

If you have concerns about how Memeo has handled your personal data, including in relation to any of the rights contained herein, please send an email to compliance@unicomsi.com outlining the concerns that you have.

You may also make a complaint to the ICO (the UK supervisory authority). You can find further information about the ICO and their complaints procedure at: https://ico.org.uk/concerns/.

IP Addresses

Memeo Websites may collect your Internet Protocol (IP) address. This information is collected for internal security and system administration purposes. This information may also be used to trace the computer used in cases of misuse or unlawful actions in connection with visits to or use of Memeo’s Websites.

External websites

Memeo’s Websites may, from time to time, contain links to other websites. If you follow a link to another website, please note that the website will have its own privacy policy and that Memeo does not accept any responsibility or liability for such policies, or how such websites collect and use your data. Please check the associated privacy policy before you submit any personal data to these websites.