This document establishes what legal conditions INIVOS LTD must comply with when handling, processing, collecting, sharing or storing any Personal Data received from you as its customer. It also explains to you what rights you have if Personal Data is being processed by INIVOS LTD.
- Personal Data about INIVOS LTD’s customers is collated from various different sources – for example, forms, web chats, email, telephone calls, technical information (IP address and URL). INIVOS LTD also receives Personal Data from other external sources, such as marketing partners and courier companies.
- Any Personal Data collected by INIVOS LTD will only be used to fulfil its legal obligations, perform the contract with the customer, or to fulfil INIVOS LTD’s (or a third party’s) legitimate interests, provided it does not compromise any relevant individual’s fundamental rights.
- An existing customer of INIVOS LTD may be contacted by electronic means in relation to similar new goods or services INIVOS LTD can provide. A prospective new customer will only be contacted by electronic means only if explicit consent has been provided to do so.
- Personal Data will only be used for the purpose for which it has been collected or a compatible purpose.
- Personal Data may be shared with subsidiary companies or other third parties such as advertising networks, analytics and search engine providers and couriers.
- Personal Data will be stored in a secure location to prevent it being accidentally lost, altered or disclosed with only authorised personnel able to access it. INIVOS LTD will require all third parties and subsidiaries to take the appropriate security measures to protect customer Personal Data which should be in line with INIVOS LTD’s policies. If there is a data breach it will be reported, investigated, evidenced in accordance with legal requirements and company procedure.
- On rare occasions Personal Data collected by INIVOS LTD may need to be transferred outside of the European Economic Area to Australia and New Zealand in order to perform the contract between the customer and INIVOS LTD or provide support services. INIVOS LTD will take the necessary steps to ensure that Personal Data is treated securely and in accordance with the INIVOS LTD’s privacy policies.
- Data will only be retained by INIVOS LTD for as long as necessary and in order to fulfil the purposes it has been collected or to satisfy any legal or accounting reporting requirements.
- Personal Data will be maintained as accurate and up to date.
- A customer can find out what information INIVOS LTD holds about them but this request must be reasonable, and if it is deemed to be excessive INIVOS LTD could decline or charge an administrative fee for the request.
For further details, information and rights related to this privacy notice please refer to Customer Privacy Notice.
Inivos Ltd (“We“) are committed to protecting and respecting your privacy and the security of your personal information.
For the purpose of the General Data Protection Regulation, the data controller is Inivos Ltd of 307 Euston Road, London, NW1 3AD.
INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
- Information you give us. This is information about you that you give us by filling in forms on our site inivos.com or by corresponding with us by phone, e-mail or during face-to-face appointments with us. It includes information you provide when you register to our website, subscribe to our services, search for a product, place an order, participate in discussion boards on our website or any other our social medial platforms run by our website, enter a competition, promotion or survey, join live chat with helpdesk support, use diary booking, when you report a problem with our site or when you meet with our staff to report the service problems. The information you give us may include your name, address, e-mail address and phone number, gender, financial and credit card information, job title, work place, personal description, and photograph.
- Information we collect about you from our site. With regard to each of your visits to our site we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs),methods used to browse away from the page, and any phone number used to call our customer service number.
- Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, inbound marketing company, telemarketing company, mailing companies and courier companies]. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
- Information we receive from database organisations. This information we receive about you from third party organisations will be stored securely as it is described in this policy. We will notify you when we receive information about you from them and how we intend to use that information.
HOW WE MAKE USE OF THE INFORMATION
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:
- Information you give to us. We will use this information:
- to carry out our obligations arising from the contract entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you.
- If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you.
- If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have explicitly consented to this. If you are happy for us to use your data in this way, and to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (online registration form);
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- Information we collect about you. We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to provide and improve content on our site to it is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
- Information we receive from other sources (described above). We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
- If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.
- Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
SHARING YOUR INFORMATION WITH THIRD PARTIES
We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
You agree that we have the right to share your personal information with:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- Selected third parties including:
- business partners, suppliers and sub-contractors, but only for the performance of any contract we enter into with you;
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. Note: We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
The following third-party service providers process personal information about you for the following purposes:
- Equinet Media – inbound marketing company
- Blueberry – telemarketing company
- Royal Mail – mail
- Couriers – UK mail, TeamC, AF Couriers, DHL, TNT, Touffnells U-Ship
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We will also disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Inivos or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
or terms and conditions of sale [provided in sales contract] and other agreements; or to protect the rights, property, or safety of Inivos, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure server called ACT! CRM system. Only selected people within Inivos are able to access your information and use for the purposes described above. Any product or service payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
TRANSFERRING INFORMATION OUTSIDE THE EEA
In rare occasions, we might need to transfer the personal information we collect about you to the following countries outside the EEA:
- New Zealand
Transfer is necessary in order to perform our contract with you. This includes transfer to organisations 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.
If you require further information about these protective measures, you can request it from our data privacy manager.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information stored at our CRM to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
HOW LONG WE RETAIN YOUR PERSONAL DATA
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In order to comply with law and to ensure we have the necessary information required in order to resolve future issues that might arise, we retain all personal data for a period of 10 years from collection. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
YOUR RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION
- Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes at any point in the future.
- Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request“). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing, which is performed safely and no personal information is left (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our privacy data manager in writing.
- No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
- What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
- Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact privacy data manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
- Issues and complaints
Under circumstances where you are not satisfied how Inivos handles your personal data you are allowed to rise a complain and we will take action to address and resolve the issue. However, if we do not provide the right solutions, you also have a right to contact ICO that has a general duty to investigate complains from members of the public.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
- Where we have notified you of the decision and given you 21 days to request a reconsideration.
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
DATA PRIVACY MANAGER
We have appointed a data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the data privacy manager. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.