PRIVACY POLICY

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS WEBSITE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS https://app-med-wp-prod-uksouth.azurewebsites.net/ (“MED WEBSITE” or “Website”).
Effective May 25th, 2018

It is important that you read this policy together with any other privacy policy or fair processing policy 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 policy supplements the other policies and is not intended to override them.

Disclaimer

While MAST Energy Developments PLC (MED) has endeavoured to ensure that all information provided on the MED Website, is accurate and up to date, MED takes no responsibility for any error or omission relating to this information. To the maximum extent permitted by law, MED will not be liable for any cost, loss or damage suffered by you through your use of MED’s Website or MED’s failure to provide access to this Internet Website or information updates.
Your use of the MED Website is governed by the MED Website Terms and Conditions of Use. This site is not intended for children and we do not knowingly collect data relating to children.

Online Privacy Policy

For the purpose of the Data Protection Act 2018, the data controller is MED Energy PLC with a registered address at 2nd Floor, Ludgate Hill, London, United Kingdom, (EC4M 7JW). If you have any questions about this policy, and/or including any data subject access requests to exercise your legal rights (which are further detailed in this policy) please email our Data Protection Officer directly at dpo@med.energy.
You have the right to make a complaint at any time to the UK Information Commissioner’s Office (https://ico.org.uk/make-a-complaint) which is the United Kingdom’s authority for data protection issues. MED would, however, appreciate the chance to deal with your concerns before you approach the DPC so kindly contact us in the first instance.
This online Privacy Policy is provided to make you aware of how MED collects, uses and manages information of visitors to its Website. MED, the publisher of the MED Website, views the personal privacy of users as an important issue, and is committed to maintaining the security of personal information provided to MED by users in accessing the Website. This policy forms part of the Terms of Use of the Website and describes how MED treats personal information that it receives through your use of the Website.
Please note: MED makes some other websites available to you from hyperlinks in www.MED.energy. These websites are not subject to MED’s Privacy Policy. You should review the privacy policy of each individual website you access via hyperlinks from this website and assess whether the policy of each website is satisfactory to you before you use the other websites. MED is not liable in any way for the content, availability or use of such hyperlinks or linked web sites and you use such hyperlinks entirely at your own risk.

What Information Do We Collect and How Is It Used?

MED collects the following standard information regarding visitors to our Website: the pages that you view, the links you click, and other actions taken in the Website. We also collect certain standard information that your browser sends to every website you visit such as your IP address (browser type, language, access times) and referring website addresses. MED collects and logs this information for statistical purposes, to administer our Website and servers and/or to allow for auditing of our services by third parties.
MED will only use your data when the law allows us to. Most commonly, MED will use your personal data in the following circumstances:

1. Consent: you have given the organisation consent to process your personal data for one or more specific purposes.
2. Contract: the processing is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into a contract.
3. Legal obligation: the processing is necessary to comply with a legal obligation which the organisation is subject to.
4. Vital interests: the processing is necessary to protect someone’s vital interests or those of another person.
5. Public task: the processing is necessary to perform a task in the public interest or an official function with a clear basis in law.
6. Legitimate interests: the processing is necessary for the purposes of pursuing the organisation’s legitimate interests or those of a third party, except where those interests are overridden by the interests or rights of the data subject which require protection.

Note that we may process your personal data for more than one of the above lawful grounds depending on the specific purpose for which we are using your data. Further details on the main legal basis/legitimate interest that we would process data under can be found in the ‘Glossary’ section of this privacy policy. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out.
Other than as stated above, no attempt is made by MED to identify users or their browsing activities except where legally required to do so, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect logs, or where MED believes it is required to collect and produce relevant electronic documentation to fulfil its obligations to third parties, including statutory organisations under local law.
MED endeavours to use and disclose your personal information only in limited circumstances. MED will do so if it is necessary to protect any copyright or intellectual property in the material on the website, or if it is necessary to enforce the MED Website Terms and Conditions of Use.

Disclosures of Your Data

MED may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 7 and 8 of the Companies Act 2014. Under certain circumstances we may disclose your personal information to third parties as well.
Disclosure conditions are as follows:

1. Among MED Internally. Depending on where you are located and the services you use. MED shares personal information with other MED sites for the five legal bases mentioned above and also in the Glossary. These affiliated sites use your information in accordance with this policy.
2. With MED Service Providers. We rely on third-party service providers to perform a variety of services on our behalf. For example, we may rely on service providers to host data and platforms, fulfil our product and service requests and answer your questions, send e-mails on our behalf and analyse data to improve our products and services. To do so, we may need to share your personal information with them for legitimate interests.
3. With Other Parties in relation to a Commercial Transaction. We will disclose your personal information in the event we sell or transfer all or a portion of a business or assets to that third party, such as in connection with, but not limited to a merger bankruptcy, reorganization, or liquidation.
4. With Other Parties When Required by Law and as Necessary. In some instances, we and our service providers disclose your personal information to law firms, auditors, consultants, the police, courts, tribunals, and other law enforcement agencies:
   1. To provide you with the services you or your company or organization request.
   2. To comply with the law or respond to legal process or a request for cooperation by a government entity or law enforcement;
   3. To detect, suppress, and prevent fraud or verify and enforce compliance with the policies governing our products and services; or
   4. To protect our rights or that of any of our respective affiliates, business partners, customers or employees and where otherwise required by law.
5. Third-Party Partners, With Your Consent. We may request your consent to share personal information about you with third parties so that they may provide you with special offers, promotional materials, and other materials that may be of interest to you.
6. Other Parties at Your Company’s or Organization’s Direction. In addition to the disclosures described in this policy, we may share information about you with third parties when your company or organization requests such sharing. For example, we periodically may partner with third parties to make products or services available to individual members or participating companies and organizations. If you or your company or organization requests to participate, we may share your information with the relevant third party in connection with the requested product or service.
7. Aggregated and Non-Personal Information. We also share with third parties, information in a manner that does not identify particular individuals, for example, information that has been aggregated with other records.
   Further Details of our External Third Parties are set out in the Glossary.
   We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our 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 our instructions.

Retention Policy

MED retains personal information only for as long as is required to communicate with its shareholders and potential investors in accordance with consent obtained through its email subscriber service. Communications sent through this service provide an unsubscribe link which is monitored by MED’s Data Protection Officer.

Security

MED takes all reasonable security measures to protect personal information from loss, unauthorised access, destruction, misuse, modification, or disclosure although MED takes such steps to protect your information, no security program is fool proof and thus we cannot guarantee the absolute security of your personal or other information; any transmission is at your own risk. As far as permissible under law, MED accepts no responsibility for the unauthorised access of personal information held by MED.
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.

Third-party marketing

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

Email Alerts Service

MED offers a free subscription service, through a third-party provider, BrighterIR, so that you may receive information about MED by e-mail. While BrighterIR endeavours to provide you with this information on a timely basis, MED cannot guarantee that delivery by e-mail will not be delayed.
Any personal data collected from this free subscription service on the Website is collected and stored responsibly and adheres to current Irish legal and professional guidelines. This personal data is stored and used by MED solely in relation to advising and updating its shareholders and prospective investors in connection with its on-going business activities. Personal data is not transmitted to 3rd parties save for sharing with BrighterIR, our marketing automation platform who process it in accordance with their Privacy Policy (available at this link).

International Transfers

The data that we collect from you may be transferred to, and stored at, a destination outside the UK as many of our external third parties are based outside the United Kingdom’s Economic Area (UKEA) so their processing of your personal data will involve a transfer of data outside the UK.
It may also be processed by staff operating outside the UK who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• Where we use certain service providers, we may use specific contracts approved by the UK Information Commissioner’s Office, which give personal data the same protection it has in the United Kingdom.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

We are aware that these safeguards depend partly on the European Commission’s judgment as to the adequacy of safeguards for personal data applicable in the receiving country and this may change over time. Please contact us on dpo@MED.energy if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Your Legal Rights

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

1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent at any time where we are relying on consent to process your personal data. However, 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

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.

Time limit to respond

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.

Issues Regarding this Website

As mentioned, you have the right to make a complaint at any time to the UK Information Commissioner’s Office (https://ico.org.uk/make-a-complaint) which is the United Kingdom’s authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office so please contact our Data Protection Officer in the first instance at dpo@med.energy.

Updating this Privacy Policy in the future

Privacy laws and guidelines are part of a constantly changing environment. We will notify you of material changes of this privacy policy by e-mail or by posting a message on our internet Website (https://app-med-wp-prod-uksouth.azurewebsites.net/). It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, and if there are any changes please let us know by contacting us on either info@med.energy or dpo@med.energy.
This version was last updated on the date noted in the header of this policy and historic versions can be obtained by contacting us on the above contact details.

Glossary

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you 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 data for our legitimate interests. We do not use your data 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 at dpo@med.energy.

Perform a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

External Third Parties

• BrighterIR
• Google Analytics