28th May 2018
Who are we?
Your privacy is very important to us. This privacy notice ("Privacy Notice") is provided by Insynth Marketing Limited ("IML"). References to "we", "our" and "us" in this Privacy Notice are references to IML. We are a controller of your personal data under applicable data protection laws, including, from 25 May 2018, the General Data Protection Regulation ("GDPR"). We, as a controller, determine why and how we collect and use your personal data.
What Is the purpose of this Privacy Notice?
When you visit our website or otherwise interact with us, we may collect information about you which constitutes personal data under the GDPR. This Privacy Notice explains how we collect, use, share and protect your personal data. Please read this Privacy Notice carefully to understand what we do with your personal data. We may change this Privacy Notice from time to time and if we make any material changes then we will make the updated Privacy Notice available to you on our website or by other means. The date at the top of this Privacy Notice indicates from when this Privacy Notice applies.
Whose personal data do we collect?
We collect and process personal data about individuals who may be current, prospective and former (i) clients (ii) suppliers or (iii) intermediaries (collectively "you").
What kind of personal data do we collect about you?
We collect from you personal data such as your name, business or residential address and email address, phone numbers, as well as any other information we ask you to provide in our website forms and your browsing activity on our website.
How do we collect your personal data?
We may collect your personal data when you (i) provide it to us in an online form, related documents and/or on our website; and (ii) provide it to us in correspondence and conversations with our representatives and intermediaries.
Do we collect personal data about you from third parties?
We also may collect your personal data such as your name, residential address, and other contact or authentication information from publicly accessible sources e.g. to find out your contact details if we are unable to contact you.
How will we use your personal data?
This section of this Privacy Notice explains for what purposes we use your personal data and on which legal bases we rely, to ensure that we process your personal data lawfully. Our legal bases for collecting and using your personal data will include:
- to perform our contract with you when you work with you.
- to pursue our or a third party's legitimate interests which do not override your interests or fundamental rights and freedoms, such as: (i) recovering debts owed by you to us; (ii) mitigating business and operational risks; (iii) complying with internal policies; (iv) ensuring network and information security (v) recording and monitoring calls and electronic communications for record keeping, security, quality, staff training and other business purposes; (vi) developing, improving and informing you about IML products and services, conferences and marketing events that may be of interest to you or the organisation you represent; (vii) maintaining the relationship and otherwise interacting with you; (viii) undertaking business analysis and market research relevant to our business; (ix) protecting IML’s interests, including establishing, exercising and defending legal rights and claims.. When evaluating whether legitimate interests can be relied on as a legal basis for the processing activities described above, a balancing test is carried out to ensure that the use of your personal data will not be overridden by your interests or fundamental rights and freedoms and you can obtain further information about the balancing test by contacting us using the contact details provided below;
- in certain circumstances and subject to applicable laws, your consent, however we will make this clear to you at the time of collection of your personal data, and you will have the right to withdraw your consent at any time.
Who do we share your personal data with?
We may share your personal data for the purposes described in this Privacy Notice with our affiliates, intermediaries, service providers, agents and delegates, such as administration agents, , auditors and other professional advisors (and their affiliates, service providers, agents and delegates). Where we use third parties who process your personal data on our behalf as a processor, we ensure they do so in accordance with our instructions and that they put appropriate technical and organisational security measures in place to adequately protect your personal data.
Where we share your personal data with our service providers, we may allow them to process it as controllers under their privacy notices solely for the purposes of providing their services to us, complying with their own (and their affiliates', service providers', agents' and delegates') legal obligations or pursuing their legitimate interests as described above in this Privacy Notice, but strictly in connection with the provision of their services to us and in accordance with applicable laws. We do not allow our service providers to market to you for their own purposes unless they obtain your consent.
In certain circumstances, we or they may inform you about how you can access their privacy notices, which will give you further information as to how they use your personal data and how you can exercise your rights in relation to your personal data.
We may disclose your personal data for the purposes set out in this Privacy Notice to other third parties e.g. courts, governmental agencies, tax and other regulatory authorities, where we are legally obliged to do so or in our reasonable opinion such disclosure is necessary to comply with applicable laws and legal processes, support an investigation or to protect our rights and interests.
We may also share your personal data with a potential buyer in connection with any proposed purchase, merger or acquisition of any part of our business.
As we operate globally, your personal data may be transferred to countries outside the European Economic Area, including the United States, India and Hong Kong. Where the level of protection of personal data in those countries has not been deemed adequate by the European Commission, we put standard data protection clauses in place (as approved by the European Commission) to provide appropriate safeguards to ensure that your personal data will remain adequately protected in accordance with applicable data protection laws. Please contact us using the contact details provided below to obtain a copy of our standard data protection clauses.
How do we protect your personal data?
To protect the security of your personal data, we implement appropriate technical and organisational security measures which include physical and technical security safeguards and a governance model that ensures that adequate policies, procedures and controls are in place within our organisations.
How long we hold your personal data for?
We may retain your personal data as long as it remains necessary in relation to the purposes we collected the information for. When determining the appropriate retention period, we consider the risks of the processing, our contractual, legal and regulatory obligations, internal data retention policies and our legitimate business interests as described in this Privacy Notice.
What are your rights in relation to the personal data we hold about you?
Subject to the conditions prescribed in applicable laws, you have the right: (i) to access, rectify or request erasure of your personal data; (ii) to ask us to restrict processing of it; (iii) to request portability of it; (iv) to object, on grounds relating to your particular situation, to processing of your personal data which is based on our or a third party's legitimate interests; and (v) to object to processing of your personal data for direct marketing purposes. You can exercise these rights by contacting us using the contact details provided below. You also have the right to lodge a complaint with a supervisory authority about our use of your personal data in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes the GDPR.
How can you contact us?
If you have any questions or concerns about our use of your personal data, please contact us in writing at Insynth Marketing Ltd, The Mansions, 43 Broadway, Shifnal, TF11 8BB, United Kingdom or at firstname.lastname@example.org .