When you register with us or otherwise use our Website, we collect and process personal data about you. This document helps you understand what personal information we collect about you, how we collect it, what we use it for, and what rights you have regarding your personal data.
Monsun Limited is the entity responsible for processing your personal data.
1 Personal data - what we collect and what we use it for
1.1 Master data
When you create a profile or write your first review on the Website, we will automatically generate a personal account for you on Sixth Element (“Account”) and collect the following personal data about you (the “Master Data”):
- Your username (this may be public)
- Your securely encrypted password, and
- Your email address.
This information is mandatory.
Please don’t share any sensitive personal documents or information with us, either concerning yourself or others.
1.3 Information about views:
If you write a review on or about our products and / or Website, people can show that they find your review useful, for example by “liking it”, and we collect this information. We may also collect information about how many people read your review. We don’t track the identities of people who aren’t logged in and read the reviews, but we do collect data on the number of consumers who read your review. If you “like” another person’s review we may also collect that information.
If you notify us about content or a review that you believe violates our User Guidelines, then we collect the information you provide in your notification to us. This can include what you notified us about, the reason for your notification, the date of your notification, etc.
1.5 Information from other services, including social networks like Facebook:
If you use this option we may collect selected information about you from your Social Networks. The information we collect depends on what information you have made available on those Social Networks and your privacy settings for sharing such information on the Social Networks. Depending on your settings and selection, we will collect the following information:
- Name and/or username
- Email address
- Profile photo
- Who your social connections are
Read more about which cookies the Website uses and for which purposes below (in 8).
1.7 Your IP address, browser settings and location
When you visit the Website, we register your computer’s IP address and browser settings. The IP address is the numerical address of the computer used to visit the Website. Browser settings can include the type of browser you use, browser language, and time zone. We collect this information so that we can trace the computer used in cases of misuse or unlawful actions in connection with visits to or use of the Website. We also use the IP address to approximate your location (at city level) and so that we know which sets of our Terms & Conditions apply to your use of our Website.
1.8 Newsletters and digest emails
We collect the information you provide us with if you subscribe to receive our newsletters, digest emails or similar (we collect your name, email address and newsletter preferences). If you no longer wish to receive our newsletters, digest emails or similar, you can unsubscribe by logging into your Account and changing your settings.
1.9 For what purposes do we use your personal information?
We will use the information you provide to us to:
- Provide our services to you, including displaying your reviews, and providing you with access to your profile and our Website
- Identify you as a registered user when you log in to the Website and re-visit the Website
- Verify the legitimacy of your reviews
- Improve the Website and our services
- Invite you to leave more reviews
- Respond to your questions and provide related customer service
- Send you our newsletters /communications
- Engage in various internal business purposes, i.e data analysis, audits, fraud monitoring and prevention, developing new products and services, improving or modifying the Website, or our services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities
- Comply with legal requirements and legal process, requests from public and governmental authorities, relevant industry standards and our internal policies and in relation to our T&Cs
- Protect our operations or those of any of our affiliates
- Protect our rights, privacy, safety or property and/or that of our affiliates, you or others
- Allow us to pursue available remedies or limit any damages that we sustain
We will also use the information in other ways for which we provide specific notice at the time of collection.
1.10 On what legal basis do we process your personal data?
We need to process your personal information in order to:
- Perform our contract with you (see Article 6.1.b of the GDPR)
- Comply with our legal obligations (see Article 6.1.c of the GDPR) and operate an online review platform in compliance with, for example, the Unfair Commercial Practices Directive, ICPEN’s guidelines on online reviews and endorsements, The Consumer Protection from Unfair Trading Regulations 2008, The Competition and Markets Authority’s guidance on online reviews and endorsements.
- Pursue legitimate business interests of our own related to operating the Website and providing our services to you, or to pursue the legitimate interests of third parties as long as your interests and fundamental rights do not override those interests (see Article 6.1.f of the GDPR).
- For the establishment, exercise or defence of legal claims, where necessary (see Article 9.2.f of the GDPR)
Some of these grounds for processing your personal data overlap, so there may be several reasons which justify us processing your personal information.
In those limited circumstances where you have expressly given your consent to us to process your personal data (see Article 6.1.a of the GDPR), for example, when subscribing to our newsletters, you are free to revoke your consent at any time. However, please be aware that we may have the right to continue to process your information if it can be justified on one of the other legal bases mentioned above.
You have the right to object to how we process your personal information, or ask us to restrict the processing. Please see below, at 13, for more details.
If you would like more information about our legal basis for processing your personal information, please contact our Data Protection Officer (DPO) - see 14, below.
2 Disclosure of personal information
2.1 Disclosure of personal information on the Website
We recommend that you exercise care in deciding which information to make available for disclosing on the Website, and be aware that depending on the level of information provided, you may or may not be anonymous.
Master Data and other information
If you write a comment / review on our Website and create an Account, your username, review, photo, location and the number of reviews you have written will be visible on the Website.
When you write a review on the Website, we use your computer’s IP address (see section 1 of this Policy, above) to approximate your location to the nearest city. This information is made available to other users of the Website.
If you connect to a Social Network, information such as your profile photo, your name, birth year and approximate location will be collected from your Social Network profile and used to identify you on the Website. Subject to your privacy settings and the level of information available from the Social Network, users of the Website can use this information to identify which reviews you have written.
If you have chosen to preserve anonymity by using a pseudonym for your username, be aware that information from Social Network(s) can reveal your identity in part or in full and make it possible to identify which reviews you have written.
2.2 Disclosure on services to which you connect your profile
2.3 Disclosure to other services, websites and companies:
We do not share the documentation you send to us. However, if you have a reference number or order ID, we may use that in the processing of your order, or in connection with your order / goods.
2.4 Other disclosures
In addition to the above, we disclose your personal information to the following parties and in the following circumstances:
- To comply with laws or to respond to claims, legal process (including but not limited to subpoenas and court orders) and requests from public and government authorities
- To cooperate with regulatory bodies and government authorities, including but not limited to Trading Standards, The Competition and Markets Authority, in connection with investigations or case referrals
- To third parties in connection with enforcement of our Terms & Conditions and Guidelines
- To third parties in order for us to protect our operations or those of our affiliates
- To third parties in order for us to pursue available remedies, or limit damages that we may sustain
- To third parties in order for us to investigate, prevent or take action regarding suspected or actual prohibited activities, including but not limited to fraud and misuse of our Website
- To a third party in the event of any reorganization, merger, acquisition, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings).
3 Data controller
3.1 Information for which we are the data controller
We are the data controller of the Master Data you enter to create and maintain your profile, which includes but is not limited to your name, password and email address, as well as the registration of your IP address.
We are also the data controller of the information which is disclosed to other services (see 2 above).
3.2 Information for which you are the data controller
You are the data controller for the content you choose to disclose on the Website, and for the personal data disclosed when you connect your Social Network profile(s) with your profile on the Website.
4 Links to websites
Our Website contains links to other websites. Our inclusion of such links does not imply that we endorse those websites. We do not control the content of those third party websites, and assume no responsibility for the third party or their policies or practices.
We encourage you to review the privacy policies for these third party websites because their procedures for collecting, handling and processing personal data will be different from ours.
5 Data processors and transfer of personal information outside the EU
We use external companies to maintain the technical operation of the Website and our services. These companies are data processors for the personal data for which we are the data controller. By accepting this Policy, you agree that we may also allow the data for which you are the data controller to be processed by these data processors.
We have data processing agreements in place with the data processors and it follows from these agreements that they must act solely in accordance with our instructions. By accepting this Policy, you authorise us to instruct the data processors to process data in accordance with the Policy and for the purposes of using the Website.
The data processors have taken reasonable technical and organisational measures to protect against the information being accidentally or illegally destroyed, becoming lost or deteriorating, and to protect against the information being disclosed to unauthorised persons, being misused, or in other ways being processed in violation of data protection laws.
On your request – and possibly in return for remuneration at the data processors' applicable hourly rates at any time for such work – the data processors must supply you with sufficient information to demonstrate that the above-mentioned technical and organisational safety measures have been taken.
Some of these data processors and third party services are located outside of the European Union, such as in the USA. You consent to us using data processors in unsecure third countries provided that there is a legal framework governing the transfer of your personal data and ensuring adequate protection of it, for example if the data processor is part of the EU-US Privacy Shield framework.
6 Data retention
We keep the Master Data and other personal data you provide, including your reviews, for as long as you have an Account or as needed to provide you with our services. If you choose to delete your Account please note that all your reviews may also be deleted. We will delete this information upon your request and we will only save a log with the following information: your name, email address and the date of the deletion of your Account. We will keep the log for up to three years. All other information will be deleted.
In some cases, even if you close your account, we then choose to retain certain information (e.g. visits to our Website) in an anonymizsd or aggregated form.
7 Security measures
We use reasonable organisational, technical and administrative measures to protect your personal information within our organisation and we regularly audit our system for vulnerabilities. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of the information you transmit to us. Emails sent via the Website may not be encrypted, and we therefore advise you not to include any confidential information in your emails to us. We are always working to improve our security practices and we will update this information as these practices evolve over time.
8.1 What types of Cookies do we use?
Cookies are small pieces of information that the Website places on your computer's hard disk, on your tablet or on your smartphone. Note that HTML5 introduced Web Storage that has a similar nature to Cookies, and that we therefore consider that as a Cookie in the following.
Cookies contain information that the Website uses to make the communication between you and your web browser more efficient. Cookies identify your computer or device rather than you as an individual user.
We use session cookies, persistent cookies, HTML5 sessionStorage and HTML5 localStorage session cookies and HTML5 session. Storage objects are temporary in nature and are deleted when you exit your web browser. Persistent cookies are permanent in nature and are stored and remain on your computer until they are deleted. Persistent cookies expire or auto delete after a certain period of time, which is set per cookie, but are renewed each time you visit the Website. HTML5 local. Storage objects are permanent in nature and remain on your computer until they are deleted.
Measuring Website traffic such as the number of visits to the Website, which domains the visitors come from, which pages they visit on the Website and in which overall geographical areas the visitors are located.
Monitoring Website performance and your use of our Website
Monitoring the performance of the Website, our applications (if present) and how you use our Website.
Authentication and improving the functionality of our Website
Optimising your experience with the Website, which includes remembering your username and password when you return to the Website, and remembering information about your browser and preferences (e.g. which language you prefer).
Connecting you to Social Networks
We may give you the option of connecting with Social Networks, such as Facebook.
Ensuring the quality of content and to prevent misuse or irregularities in connection with using the Website.
8.3 Third party Cookies
Third party Cookies are set by third party websites – not our Website. When you visit our Website, the following third party Cookies may be set:
- Facebook cookies, set when you log in to our Website with Facebook
- Google cookies, set when you log in to our Website with Google
- Google AdSense cookies, set when displaying relevant targeted advertisements on our Website. Some cookies may be set as DoubleClick, which is part of Google
- New Relic cookies, set when monitoring and analysing the performance of our applications and metrics from user sessions.
- Hotjar localStorage, set for managing how and when surveys are displayed.
8.4 Deletion of cookies
You can delete the cookies already on your device. You can typically delete cookies from the Privacy or History area, available from the Settings or Options menu in the browser. In most browsers, the same menu can be reached through the Ctrl+Shift+Del keyboard shortcut or Command+Shift+Del if you're on a Mac.
If you do not accept Cookies from our Website, you may experience inconvenience in your use of the Website, and you may be prevented from accessing some of its features.
9 Access and insights into the personal data we have about you
If you have an Account you can ask us to see what information we have about you.
If you don’t have an Account, you can email us and request information about your personal data. Upon receiving your request, we will let you know what personal information we have about you, how we collect the information, the purpose for which we process your personal data, and who we share your personal information with.
10 Download your personal data (data portability)
On request, we can allow you to download the personal data that you have provided to us.
11 Correction and deletion of your personal data
If any of the Master Data or other personal information that we have about you in our capacity as a data controller is incorrect or misleading, you can ask us to correct the information.
If your personal information changes, please inform us by email.
If your Account is deleted, all the data associated with your Account will be deleted, including your Master Data and reviews on the Website.
We reserve the right to block access to your Account and/or delete it if the Account or the content associated with your Account or your review(s) on the Website is, in our assessment, discriminating, racist, sexually oriented, unethical, threatening, offensive, harassing or otherwise violates applicable laws, third party rights or our User Guidelines, or is inconsistent with the purpose of the Website. If we block access to or delete your Account, we will inform you of the reason for blocking or deleting your Account by sending an email to the address you provided when you created your Account.
12 Other rights
In addition to the rights set out above concerning your personal data, you also have the following rights:
- You also have the right to object to the processing of your personal data and have the processing of your personal data restricted.
- In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.
- If our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing of data carried out before you withdrew your consent. You may withdraw your consent by emailing us
In some circumstances, these rights may be limited or conditional. For example, whether or not you have the right to data portability in a particular case depends on the specific circumstances of the processing activity.
13 Children’s information
If you become aware that a child under the age of 13 years old has provided us with their personal information, please contact us by email to firstname.lastname@example.org
14 Our Data Protection Officer
We have a Data Protection Officer (DPO). If you have any questions about the data processing activities performed by us, you are welcome to contact our DPO by email to email@example.com
15 Changes to this Policy
We reserve the right to make changes to this Policy. The date shown at the start of this Policy indicates when it was last revised. If we make material changes to it, we will provide notice through our Website, or by other means, to give you the opportunity to review the changes before they come into effect. If you object to our changes, you can close your account. Your continued use of our Website after we publish or send a notice about the changes to the Policy will mean that you accept and agree to the updated Policy.
16 Contact information and where to send questions or complaints
If you have questions or concerns about our Policy, how we process your personal information, or would like us to correct your personal information, feel free to contact us by email to firstname.lastname@example.org
You can also reach us by post at 14 Church Road Urmston Manchester M41 9BU, U.K.
If contacting us does not resolve your complaint, you have further options, for example you may always lodge a complaint with a data protection supervisory authority.