Where we refer to “process”, it relates to how maxwell+spark will collect, use, store, make available, destroy, update, disclose, or otherwise deal with your personal information.
Generally, we will only process your personal information if this is required to deliver or offer a service, provide a product or carry out a transaction.
We may combine your personal information and use the combined personal information for any of the purposes stated in this Privacy Policy. Any reference to “we” or “us” or “our” includes maxwell+spark and any of its subsidiaries. If you use our services, goods, products, and service channels you agree that we may process your personal information as explained under this Privacy Policy. Sometimes, you may provide us with consent to process your personal information.
As a global organisation, this Privacy Policy will apply to the processing of personal information by any member of our company globally. If we process personal information for another party under a contract or a mandate, the other party’s privacy policy will apply to the processing.
We can change this Privacy Policy from time to time if the law or its business practices requires it.
The version of the Privacy Policy displayed on our website will apply to your interactions with us.
What is personal information?
Personal information refers to any information that identifies you or specifically relates to you. Personal information includes, but is not limited to, the following information about you:
- Full Name/s
- Contact Details which could include e-mail address, physical address (like residential address, work address or your physical location) and telephone number.
- Biometric information (like fingerprints, your signature or voice).
- Confidential correspondence
When will we process your personal information?
maxwell+spark will only process your personal information for lawful purposes relating to our business if the following applies:
- if you have consented thereto.
- if a person legally authorised by you, the law, or a court, has consented thereto.
- if it is necessary to conclude or perform under a contract, we have with you.
- if the law requires or permits it.
- if it is required to protect or pursue your, our or a third party’s legitimate interest.
Reasons we need to process your personal information.
maxwell+spark will process your personal information for the following reasons:
- to provide you with products, goods, and services
- to market our products, goods, and services to you.
- to respond to your enquiries and complaints.
- to comply with legislative, regulatory, risk and compliance requirements (including directives, sanctions, and rules), voluntary and involuntary codes of conduct and industry agreements or to fulfil reporting requirements and information requests.
- to conduct market and behavioural research, including scoring and analysis to determine if you qualify for products and services or to determine your credit or insurance risk.
- to develop, test and improve products and services for you.
- for historical, statistical and research purposes, like market segmentation.
- to process payment instruments.
- to create, manufacture and print payment issues
- to enable us to deliver goods, documents, or notices to you.
- for security, identity verification and to check the accuracy of your personal information.
- to communicate with you and carry out your instructions and requests.
When how and with whom we share your personal information?
maxwell+spark will only share your personal information if any one or more of the following apply:
- if you have consented to this.
- if it is necessary to conclude or perform under a contract, we have with you.
- if the law requires it; and / or
- if it’s necessary to protect or pursue your, our or a third party’s legitimate interest.
Under what circumstances will we transfer your information to other countries?
maxwell+spark will only transfer your personal information to third parties in another country in any one or more of the following circumstances:
- where your personal information will be adequately protected under the other country’s laws or an agreement with the third-party recipient.
- where the transfer is necessary to enter or perform under a contract with you, or a contract with a third party that is in your interest.
- where you have consented to the transfer.
This transfer will happen within the requirements and safeguards of the law. Where possible, the party processing your personal information in the other country will agree to apply the same level of protection as available by law in your country or if the other country’s laws provide better protection the other country’s laws would be agreed to and applied.
An example of us transferring your personal information to another country is where foreign payments take place if you purchase goods or services in a foreign country.
TAKE NOTE: We are a global organisation. Your personal information may be shared within all our company entities in other countries and processed in those countries.
You have the right to request access to the personal information we have about you by contacting us. This includes requesting:
- confirmation that we hold your personal information.
- a copy or description of the record containing your personal information; and
- the identity or categories of third parties who have had access to your personal information.
We will attend to requests for access to personal information within a reasonable time. You may be required to pay a reasonable fee to receive copies or descriptions of records, or information about third parties. We will inform you of the fee before attending to your request.
Please note that the law may limit your right to access information.
You have the right to request us to correct or delete the personal information we have about you if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully or we are no longer authorised to keep it. You must inform us of your request in writing.
You may object on reasonable grounds to the processing of your personal information.
We will not be able to give effect to your objection if the processing of your personal information was and is permitted by law; you have provided consent to the processing and our processing done according to your consent or the processing is necessary to conclude or perform under a contract with you.
Where you have provided your consent for the processing of your personal information, you may withdraw your consent. If you withdraw your consent, we will explain the consequences to you. We may proceed to process your personal information even if you have withdrawn your consent if the law permits or requires it. It may take up to 15 business days for the change to reflect on our systems, during this time we may still process your personal information. You must inform us of any objection in writing.
You have a right to file a complaint with us or any Regulator with jurisdiction about an alleged contravention of the protection of your personal information by us. We will address your complaint as far as possible.
How we secure your personal information
maxwell+spark will take appropriate and reasonable technical and organisational steps to protect your personal information according to industry best practices. Our security measures (including physical, technological, and procedural safeguards) will be appropriate and reasonable. This includes the following:
- keeping our systems secure (like monitoring access and usage)
- storing our records securely.
- controlling the access to our buildings, systems and/or records; and
- safely destroying or deleting records.
- ensure compliance with international ISO security standards.
How long do we keep your personal information?
maxwell+spark will keep your personal information for as long as:
- the law requires us to keep it.
- a contract between you and us requires us to keep it.
- you have consented for us keeping it.
- we are required to keep it to achieve the purposes listed in this Privacy Policy.
- we require it for statistical or research purposes.
- a code of conduct requires us to keep it; and / or
- we require it for our lawful business purposes.
Take note: We may keep your personal information even if you no longer have a relationship with us, for the historical data that may be required by your employer or employee.
Our cookie policy
A cookie is a small piece of data sent from our websites or applications to your computer or device hard drive or Internet browser where it is saved.
The cookie contains information to personalise your experience on our websites or applications and may improve your experience on the websites or applications. The cookie will also identify your device, like the computer or smart phone.
By using our websites or applications you agree that cookies may be forwarded from the relevant website or application to your computer or device. The cookie will enable us to know that you have visited the website or application before and will identify you. We may also use the cookie to prevent fraud and for analytics.