Please read and review the following privacy notice carefully before using this website or other Marken platforms
We at Marken, along with our subsidiaries and affiliates (collectively, "Marken", “we”, “us”), care about your privacy and the trust you place in us by providing personal data and we want to be transparent about how we use it and how we protect it. Our privacy practices may vary among the countries or territories in which we operate to reflect local practices and legal requirements.
Last Updated: 05 October 2023
Marken has prepared this Privacy Notice (“Notice“) for:
- all visitors or users of online.marken.com, marken.com, and any successor website or application thereto (collectively, the “website“);
- all visitors or users of Marken Maestro™, Marken Allegro™, Marken Solo™, Marken Fast Track™ and Marken Apollo™ (collectively “Marken platforms”);
- any individual who interacts with Marken via Marken website ((including online job applicants), emails, call center;
- any individual who receives promotional communications from Marken;
- all visitors of Marken premises where surveillance is installed for occupational safety and crime prevention purposes;
(Collectively, the “Individuals” or “you“)https://www.marken.com/contact/web-site-terms-conditions-of-use/https://www.marken.com/contact/cookie-policy/
NOTICE: Marken has additional privacy notices or terms that are tailored for the different ways your personal data is collected by different Marken service lines or functions. For example, Marken provides employment applicants with a notice that describes the personal data we may collect in connection with Marken’s employment and recruiting efforts. If you receive a privacy notice provided to you for a specific purpose, the terms of the more specific notice or contract will control your interaction with Marken to the extent that notice conflicts with this notice.
Agreement to Terms of This Notice
By accessing Marken platforms and using the website after the notification banner or message appears on the website, and any subsequent times thereafter, you expressly agree to the terms of this Privacy Notice and consent to the collection and use of your data as set forth herein. If you do not agree to this Privacy Notice, you are not authorized to access the website or use any of its features and must immediately discontinue use of the website or other Marken Platforms.
Select one of the links below to jump to the listed section:
- Personal Data Marken Collects
- How We Use Your Personal Data And Our Legal Basis
- Sharing The Data We Collect
- Online Tracking
- International Transfers Of Your Personal Data
- Your Rights And Choices To Control Your Personal Data
- Your California Privacy Rights
- Privacy Of Children
- How Long Does Marken Keep Your Personal Data?
- Keeping Your Personal Data Secure
- Dispute Resolution And Agreement To Arbitrate
- CCTV Statement
- How To Contact Us?
- Changes To This Notice
1 Personal Data Marken Collects
For the general purposes of this Notice, personal data means any information that is linked or reasonably linkable to an identified or identifiable natural person.
1.1 Data We Directly Collect from You
You may voluntarily provide us with information about you when you interact with us, including but not limited to enabling us to receive and respond to your queries, provide you with our online services (e.g., shipment tracking) contact you with information about our services, and enable your login access to certain areas or services and applications(such as the Marken platforms).
NOTE: When providing an email address, all users assume responsibility that they are the exclusive user of the provided email address. For this reason, any liability for logins related to an email address shall be borne exclusively by the user who provided the email address.
|Category of Personal Data||Source(s)||Purpose(s)||Disclosure to third parties|
|Identifiers which may include name, alias, postal address, unique personal identifier, email address, telephone number, queries you submit to us, marketing preferences or other similar identifiers||Directly from you||To fulfill or meet the reason you provided thedata, e.g., communicating with you concerning business administration such as services and billing. To pick up or deliver a shipment or provide other services||Disclosure for business purposes to: Internet Service Providers and third-party Service Providers who perform services on our behalf based on our instruction as required on a need to know basis|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), which may include Individual and business contact information, Shipping information education, employment, employment history||Directly from you||To fulfil or meet the reason you provided the information, e.g., to respond to an inquiry, to update our Apollo database . To pick up or deliver a shipment or provide other services.||Disclosure for business purposes to internet Service Providers and to Third Party providers as required e.g. Clinical Trial conduct|
|Professional credentials, which may include your CV and other qualifications and education data||Directly from you or on your behalf||To fulfill or meet the reason you provided the data||Disclosure for business purposes to clinical trial investigators and other required parties who need to know, Service Provider of a digital platform for job applications management, and other related parties|
|Communications that we exchange when you contact our Customer services||Directly from you||Restricted access internally only for training and quality assurance purposes||We do not disclose your communications with us with Third parties unless it is legally required.|
|Audio, electronic, visual, or other sensory data, such as photographs and audio/video recordings.||Directly from you when you visit our premises||We do not disclose your communications with us with Third parties unless it is legally required.|
1.2 Data We Collect About You
|Category of Personal Data||Source(s)||Purpose(s)||Disclosure to third parties|
|Identifiers we may indirectly receive about you, which may include online identifier, Internet Protocol address, Geolocation, or other similar identifiers provided you have granted us access to that information in your device settings||Indirectly from you (e.g., from observing your actions on our website, device) * From third-party Service Providers*||To improve and personalize the Services and develop new one. For example, we may use the data to troubleshoot and protect against errors; perform data analysis and testing; or to develop new features and Services.||Disclosure for business purposes to: Internet Service Providers and third-party Service Providers maintaining our website.|
|Internet or other similar network activity, which may include browsing history, search history, information on a consumer’s interaction with a website, application||Indirectly from you (e.g., from observing your actions on our website)* From third-party Service Provider, such as a data analytics provider*||To fulfill or meet the reason you provided the data, e.g., to provide user experience on the website.||Disclosure for business purposes to third party Service Providers|
|Aggregated data, such as statistical or demographic data. For example, we may aggregate data about your use of Marken website and calculate the percentage of users accessing a specific feature.||Indirectly from you (e.g., from observing your actions on our website)* NOTE: if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data||To conduct research on the efficacy of our Services and to identify where we can improve, or to provide anonymized reports to analyze the usage, uptake and efficacy of our Service services and tools.||Disclosure for business purposes to third party Service Providers|
* Provided you have granted us access to that information in your device settings and by selections using the Cookie banner where this is relevant for your geographical location.
1.3 Data We Receive from Third-Party Sources
1.3.1 Cookie information
If you are an EU Data Subject, we only use non-essential cookies and GIFS (e.g., to enhance and personalize your experience) when you opt-in to allow for their use. However, some essential cookies are necessary for our website to function properly (.e.g. to register your opt-out decision) and will remain in use even if you do not opt-in to our use of non-essential cookies.
For more information on Cookie in general visit https://allaboutcookies.org
1.3.2 Marketing analytics information
We may also collect information about your interactions with our marketing and promotional emails (where we are entitled to contact you with such communications). This information is provided to us by marketing analytics providers that we engage to monitor our marketing performance with a view to improve our campaigns and reach out to you in a better way.
1.3.3 Social media analytics information
We may also collect information about your interactions with Marken on social media. This information includes, for example, “likes”, “share”, “follow” actions and your comments to Marken content (e.g., if you share a Marken website page on social media). We gather this information through third-party social media analytics providers that we engage for this purpose. We use this information only at an aggregate and anonymised level to measure the impact of and improve our content or marketing campaigns. Social media features and widgets may be hosted by a third party. Your interactions with those features are governed by the privacy policies of the companies that provide them.
2 How We Use Your Personal Data and Our Legal Basis
In certain jurisdictions, such as the Member States of the European Union, we are required to identify the legal bases for processing personal data. Here, we provide additional information regarding the purposes of collection and our legal bases for collecting data from you.
|We may use your personal data to:||What is the legal basis for us using your data for this purpose?|
|Provide you with customer reserved access to our website or designated Marken platforms for shipment tracking and similar services. In particular, we need to authorise and verify your identity.||Fulfil a contract, where the data is it is necessary to deliver a service you or your company you work for have requested. Legitimate interest to provide you with reserved access to our website. We believe that our legitimate interest overrides your privacy rights (also considering the adequate security measures we implement to protect your personal data).|
|Provide you with technical assistance to access and use our online services (e.g., if you have lost or forgotten your password to access Marken Maestro™, Marken Allegro™, Marken Solo™ or Marken Apollo™).||Fulfil a contract, where the data is it is necessary to deliver a service, you have requested. Legitimate interest to enable your usage of our online services as well as your interest to access such services. We believe that our legitimate interest overrides your privacy rights (also considering the adequate security measures we implement to protect your personal data).|
|Ensure the security of the data we hold about you and our website (e.g., implementation of safeguards against illegal or fraudulent activity such as cyber-attacks).||Legitimate interest to monitor how our website is used to detect and prevent fraud, other crimes and the misuse of our website. This helps us to ensure that you can safely use our website. It is also our legal obligation to protect your personal data with adequate technical measures.|
|Respond to your enquiries (via email, phone call, or online form).||Legitimate interest to provide you with the information you have requested to us or respond to your enquiries. It is also in your interest to receive a response and being contacted for enquiries you have voluntarily submitted. We believe that our legitimate interest overrides your privacy rights. In order to protect your personal data, we implement adequate security measures. With Your Consent: In cases where we need your consent to process your personal data, we will ask you to make a positive indication (e.g., to tick a box, sign a document, provide confirmation) that you agree to the processing. .|
|Provide you with access to and use of the Marken platforms, which allow you to interact with us, obtain valuable information about your products and shipments, and in relation to Home Health Care (“HHC”) Services to allow you to access and record information on Marken Apollo.||Legitimate interest to offer an added value to our logistics and storage services which enables you access important information about your shipment or the storage of your products. Depending on the Marken platform used, this can include making and updating a booking, reviewing shipment status, tracking dispatch status and reviewing storage information. In relation to Marken Apollo this can include arranging health care professional visits and storage of information in relation to the HHC Services. We believe that our legitimate interest overrides your privacy rights. In order to protect your personal data, we implement adequate security measures. Fulfil a contract, where the data is it is necessary to deliver a service you have requested. With Your Consent: In cases where we need your consent to process your personal data, we will ask you to make a positive indication (e.g., to tick a box, sign a document, provide confirmation) that you agree to the processing.|
|Contact you to update you about us, our services and promotions (provided you have consented to this where required under applicable law). For example, we could email you to invite you to an event or tell you about a new service offer.||With Your Consent: In cases where we need your consent to process your personal data, we will ask you to make a positive indication (e.g., to tick a box, sign a document, provide confirmation) that you agree to the processing. Legitimate interest: Where consent is not required by applicable law, we will rely on the necessity to pursue our legitimate interest to promote our materials in a way which respects your privacy rights and enables you to object to this use of your personal data and opt-out from our marketing communications at any time.|
|Conduct marketing research and analytics to analyse and improve our marketing campaigns (as explained above at “What categories of personal data does Marken collect about you?”).||Legitimate interest to monitor the performance and results of our marketing efforts with a view to constantly improve our marketing actions and better tailor them to our audience’s interests. We believe that our legitimate interest overrides your privacy rights. In order to protect your personal data, we implement adequate security measures. With Your Consent: In cases where we need your consent to process your personal data, we will ask you to make a positive indication (e.g., to tick a box, sign a document, provide confirmation) that you agree to the processing|
|Analyse and improve our profile and impact on social media. As explained above (at “What categories of personal data does Marken collect about you?”), the data we collect for this purpose is processed by us (or on our behalf) in aggregate and anonymised form.||Legitimate interest to monitor the performance and results of our marketing efforts with a view to constantly improve our marketing actions and better tailor them to our audience’s interests. We believe that our legitimate interest overrides your privacy rights. In order to protect your personal data, we implement adequate security measures.|
|Comply with legal requirements and assist government and law enforcement agencies or regulators/supervisors.||Data processing is necessary for the purposes of complying with legal requirements to which we are subject.|
|Improve our website (accessibility, usability, user-friendliness, interaction with external links and plug-ins, etc.). For this purpose, we may collect personal data which is then processed in aggregate form.||Data processing is necessary to pursue our legitimate interest to improve your experience and usability of our website. We believe that it is in your interest too to receive from us enhanced website services. We believe that our legitimate interest overrides your privacy rights. In order to protect your personal data, we implement adequate security measures.|
|Auditing compliance with current Notice specification and other standards and/or legislations;||Data Processing is necessary for the purposes of compliance with regulatory/legislative requirements.|
|Record and manage your marketing choices (e.g., record your opt-in to marketing where opt-in is required by applicable law and keep an up-to-date suppression list where you have asked not to be contacted, so we do not inadvertently re-contact you).||With Your Consent: In cases where we need your consent to process your personal data, we will ask you to make a positive indication (e.g., to tick a box, sign a document, provide confirmation) that you agree to the processing We need to process this information about you to address your rights and abide by our obligations under applicable law.|
3 Sharing the Data We Collect
3.1 Third Party Transfers
3.1.1 Marken / UPS group of companies
As Marken is part of a wider group with headquarters in the US, and offices located across the globe, which all collaborate and partially share customer services and systems including website-related services and systems, we may need to transfer your personal data to, or otherwise allow access to such data by other companies within the Marken and UPS group for the purposes set out above (under ” How We Use Your Personal Data and Our Legal Basis?”) including, for example, addressing your queries, providing you with our website services (e.g. shipment tracking) from any locations you request them, ensuring the security of our website and your personal data, informing you about our services and promotions.
3.1.2 Our service providers and other parties
We use other companies, agents or contractors (“Service Providers“) to perform services on our behalf or to assist us with the provision of services to you. We may share personal data with the following categories of third-party Service Provider:
- infrastructure and IT services providers.
- provider of a digital platform for job applications management.
- digital and email marketing platform.
- logistics and home healthcare sub-processors.
In the course of providing such services, these third-party Service Providers may have access to your personal data. However, we will only provide our third-party Service Providers with the information that is necessary for them to perform the services, and we ask them not to use your data for any other purpose. We may also share your data with third parties as required in order to provide our services. We will always use our best efforts to ensure that all the Service Providers we work with will keep your personal data secure.
3.1.3 Third parties permitted by law
In certain circumstances, we may be required to disclose or share your personal data in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal data to customs brokers, the police, or to judicial or administrative authorities).
We may also disclose your personal data to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our contractual rights or protect your rights or those of the public.
3.1.4 Third parties connected with corporate transactions
We may transfer your personal data to third parties in connection with a reorganisation, restructuring, merger, assignment, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal data in a manner consistent with this Notice.
3.2 Third-Party Links
When you use the websites, there may be links and you may be directed to third party websites. We are not responsible for the privacy practices or content of such other third-party sites. If you have any questions about how these other sites use your data, you should review their policies and contact them directly.
4 Online Tracking
Our website current does not use tools to enable cross contextual behaviour advertising.
5 International Transfers of Your Personal Data
Marken operates on a global basis, and your personal data may be transferred, accessed and stored globally as necessary for the uses stated in this notice, or in another notice or agreement provided to you (for example, in the US), including within the Marken and UPS group or through the use of third parties as set out under the section “Third Party Transfers” above. It may also be processed by staff operating outside the EEA who work for us or for one of our Service Providers.
Marken will take all necessary measures to ensure that your personal data is securely transferred, stored and used after transfer, as required by applicable law. This includes using appropriate safeguards such as the EU Model Contract Clauses (or equivalent measures). You can ask for a copy of the appropriate safeguards by contacting us as set out below (“How To Contact Us?“).
6 Your Rights and Choices To Control Your Personal Data
6.1 Your Rights
Depending on your jurisdiction, you may have a number of rights in relation to the personal data that we hold about you. We are committed to address these rights where required under applicable law. These can be summarised as follows.
- Know and Access. Subject to applicable law, you may have the right to know and access what data/personal information we collect about you and request a copy of the personal data we are processing about you by contacting us as indicated in the “How To Contact Us” section of this Privacy Notice. This request may include categories of sources we collect the information from, categories and/or specific pieces of personal data, categories of third parties with whom we disclose personal data and categories of what personal data is or disclosed, as well as the purpose for all of the above. Upon request, we will provide this information to you in a structured, commonly used, and machine-readable format. For your own privacy and security, in our discretion we may require you to prove your identity before providing the requested information. If you require multiple copies of your personal data, we may charge a reasonable administration fee.
- Rectification. If you believe that personal data we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the data by contacting us as indicated in the “How To Contact Us” section of this Privacy Notice.
- Deletion / Right to be Forgotten. You may have the right to request that we delete personal data that we process about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal or regulatory obligation or to establish, exercise or defend legal claims.
- Restriction. You may have the right to restrict our processing of your personal data where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
- Portability. You may have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal data which you have provided to us, and (b) if we are processing that data on the basis of your consent (such as for direct marketing communications) or to perform a contract with you (such as to administer your account).
- Objection. Where the legal justification for our processing of your personal data is our legitimate interest, you may have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
- Withdrawing Consent. In certain jurisdictions, when we process personal data based on your consent, you have the right to withdraw your consent in whole or in part at any time, free of charge. This includes cases where you wish to opt out from marketing messages that you receive from us. When unsubscribing from our marketing communications, note that because emails are planned in advance, you may still receive mailings while we process your request. Where applicable, once we have received notification that you have withdrawn your consent, we will no longer process the personal data for the purpose(s) to which you originally consented unless there are compelling legitimate grounds that override your interests, rights and freedoms (for example, to comply with a legal obligation), or for the establishment, exercise, or defense of legal claims.
- Marketing. You may elect to receive recurring informational/promotional e-mail from us. Our e-mail correspondence will include instructions on how to unsubscribe from our e-mails. Please follow the instructions in the e-mails to opt-out of an e-mail. We will unsubscribe you from that newsletter or other programs within 30 business days.
- Right to Opt-out of the Sale of Personal Data. We do not sell or monetize your personal data. We do not share your personal data with third parties for their direct marketing purposes.
- Right to Non-Discrimination. We will not treat you differently for exercising a legal right regarding your personal data.
6.2 How to exercise your rights
For requests submitted by California residents, you may use the webform available here or call the Patient Communications Center (PCC) at 844-627-5361. California residents may use an authorized agent. Authorized agents must have written permission to submit requests on your behalf.
If you are based in, or the issue relates to, the UK, the Information Commissioner’s Office can be contacted as follows:
Telephone: +44 0303 123 1113
If you are a resident or the issue took place in the European Economic Area (EEA), you have the right to lodge a complaint, The Data Protection Supervisory Authority will be the Data Protection Supervisory Authority that is local to you in your country as the data subject. A list of EU Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
The lead supervisory authority for Marken in Europe is the Data Protection Authority in Belgium (see: https://www.dataprotectionauthority.be/citizen), You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws.
People residing in non-EEA countries can contact Marken (see “How To Contact Us” section below) and/or lodge a complaint to their own national or State body regulating data protection.
Whenever feasible for verification, we will match the identifying information provided by you to the personal data already maintained by us. If, however, we cannot verify your identity from the data already maintained by us, we may request additional information.
6.3 Agent Authorization
You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us via the information provided in the “How to Contact Us” section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require:
- The authorized agent to provide proof that you provided signed permission to the authorized agent to submit the request
- You to verify your identity directly with us; or
- You to directly confirm with us that you provided the authorized agent permission to submit the request.
7 Your California Privacy Rights
For the purposes of compliance with the California Consumer Privacy Act of 2018, as amended, (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), when we use the term personal data in this Section, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
California Civil Code Section 1798.83 permit California residents to request certain information, , regarding disclosure of personal data to third parties for their direct marketing purposes. Additionally, California residents have the rights to know, to delete, to opt-out of the sale of personal data, and non-discrimination specified in the “Your Rights And Choices To Control Your Personal Data” section above.
7.2 Data Sharing for Marketing Purposes
We do not disclose your personal information to third parties for their direct marketing purposes.
8 Privacy Of Children
We do not collect the data of any individual under 16 years of age unless that individual is enrolled in a clinical trial for which we are engaged to provide services. In the event that we learn that a child under the age of 16 has provided personal data to us other than in the context of a clinical trial, we will take the appropriate steps to delete or destroy such personal data as soon as possible.
9 How Long Does Marken Keep Your Personal Data?
Your personal data is stored by us and/or our Service Providers on our behalf, strictly to the extent necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes for which the data is collected (you can see a list of these purposes under above at “ How Do Use Your Personal Data And Our Legal Basis ?”). When personal data is kept, that period will be determined based on the applicable local law. When we no longer need to use your data for any of our purposes, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it (unless we need to keep your data to comply with legal or regulatory obligations to which we are subject).
10 Keeping Your Personal Data Secure
We have implemented technical and organizational security measures, in an effort to safeguard the personal data in our custody and control. Such measures we have implemented include, for example, limiting access to personal data only to employees and authorized Service Providers who need to know such data for the purposes described in this Notice, as well as other administrative, technical and physical safeguards such as encryption when receiving and transmitting data.
While we endeavor to always protect our systems, websites, operations and information against unauthorized access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any data, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers. Understand that any data that you transfer to us is done at your own risk.
11 Dispute Resolution and Agreement to Arbitrate
Except where and to the extent prohibited by law, by using our services, you agree that, if there is any controversy, claim, action, or dispute arising out of or related to your use of our services, or the breach, enforcement, interpretation, or validity of this Notice or any part of it (“Dispute”), both parties shall first try in good faith to settle such Dispute by providing written notice to the other party describing the facts and circumstances of the Dispute and allowing the receiving party thirty (30) days in which to respond to or settle the Dispute. Notice shall be sent to:
- Us at Ground Floor, 107 Power Road, Chiswick, London, W4 5PY, UK, or
- You, at the address we have on file for you.
Both you and Marken agree that this dispute resolution procedure is a condition precedent that must be satisfied before initiating any litigation or filing any claim against the other party. IF ANY DISPUTE CANNOT BE RESOLVED BY THE ABOVE DISPUTE RESOLUTION PROCEDURE, YOU AGREE THAT THE SOLE AND EXCLUSIVE JURISDICTION FOR SUCH DISPUTE WILL BE DECIDED BY BINDING ARBITRATION ON AN INDIVIDUAL BASIS. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WILL NOT HAVE, AND YOU WAIVE, THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND THAT YOU MAY NOT PROCEED IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE CAPACITY. Other rights that you and we would otherwise have in court will not be available or will be more limited in arbitration, including discovery and appeal rights. All such disputes shall be exclusively submitted to JAMS (www.jamsadr.com) for binding arbitration under its rules then in effect, before one arbitrator to be mutually agreed upon by both parties.
The arbitrator, and not any federal, state, or local court or agency, shall have exclusive authority to resolve any dispute arising under or relating to the interpretation, applicability, enforceability, or formation of this Notice, including any claim that all or any part of this Notice is void or voidable.
12 CCTV Statement
Marken uses CCTV (Closed Circuit Television) in certain of our global locations to record employees, contractors and visitors to our premises.
12.2 The Purpose Of CCTV
Marken has a legitimate interest in maintaining the security of our facilities. We also have a duty to take reasonable and appropriate steps to provide a safe and secure working environment. Marken deploys CCTV at our locations for the following purposes:
- Enhancing the safety of Marken Personnel and visitors;
- Securing Marken client property, the Marken premises, information, and other assets;
- Deterring and detecting unlawful behavior or behavior that materially violates Marken policy;
- Responding to lawful requests from law enforcement, discovery requests, and court orders; and
- Defending or pursuing the legal rights of Marken, including the prosecution of criminal behavior.
In exceptional circumstances (such as in the case of a catastrophic event with immediate impact on the life or safety of employees, such as a fire, natural disaster, violence), Marken may use CCTV systems to visually monitor the health and/or behavior of personnel or other persons. Unless such use is required to support the vital interests of individuals, Marken will ensure there is a proper legal basis for such processing, such as prior consent.
Marken CCTV systems are used to investigate incidents in connection with the above purposes and to secure evidence related to them. Marken CCTV systems are not used to routinely monitor the work or office attendance habits of Personnel.
12.3 Location Of CCTV Cameras
CCTV cameras are located in order to monitor only those areas intended to be monitored by the equipment and to limit the capture of images or footage (e.g., street views) that are not intended to be monitored. Marken will not install CCTV cameras areas in which individuals would have an expectation of privacy such as toilets, changing rooms, etc. CCTV cameras are installed where they are visible to individuals in the area surveyed by the camera.
12.4 CCTV Signage
All locations that are monitored by CCTV will have appropriate signage. CCTV Camera locations.
12.5 CCTV System Controls
CCTV footage is stored on a secure hard drive or similar storage device and shall be maintained in accordance with the requirements of Marken Information Security policies and standards.
Access to the CCTV system is restricted to authorized personnel only, on a need-to-know basis. All personnel who may require access to CCTV footage on the system are trained on the proper use of the system and subject to written confidentiality obligations to Marken. A log of access to CCTV System and the footage stored on it, and actions taken with respect to the footage or the system, will be maintained. All requests for access to footage or images are documented. All lawful requests to access CCTV footage or images must be approved by appropriate parties within Marken. The exercise of rights by individuals is set out in “Your Rights And Choices To Control Your personal data”. Disclosure of CCTV system footage or images to third parties will be made only in accordance with the purposes for which the CCTV system is used.
Marken retains CCTV footage for a maximum of 90 days or for as long as permitted in local law, unless a longer retention period is required or permitted by law (for example, to comply with legal holds). CCTV footage images will be permanently destroyed following the expiration of the Retention Period.
Marken has implemented policies and procedures to address non-compliance with the principles outlined in this statement and consequently any violation of Federal, state, or foreign law.
13 How To Contact Us?
If you have any questions or concerns about how we treat your personal data, or you wish to exercise any of the rights described above, please contact the Marken Privacy Office at:
Telephone: +44 (0) 203 249 7508
Address: Ground Floor, 107 Power Road, Chiswick, London, W4 5PY, UK
You can also contact Marken’s Data Protection Officer, HewardMills Ltd., at:
Telephone: +44 (0) 204 540 5853
Address: 77 Farringdon Road, London, EC1M 3JU
Residents of California may also use the webform available here or call the Patient Communications Center (PCC) at 844-627-5361 to exercise their rights.
14 Changes To This Notice
We may update this Notice from time to time in response to changing legal, regulatory or operational requirements. Please review this Notice periodically to stay informed on how we are handing your personal data.
If we decide to make material changes to this Notice, we will notify you of these changes (including when they will take effect) by posting an alert on the home page of our website and / or by sending you an email at the email address we have on file for you.