Privacy policy – i-Realise Ltd

  1. Introduction
    1. We are committed to safeguarding the privacy of our website visitors and service users.
    2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that data.
    3. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy. These cookies help us to analyse traffic to see things like the effectiveness of our internet content/advertising in driving people to our website.
    4. Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications. You can opt-out by emailing clovett@i-realise.co.uk
    5. In this policy, "we", "us" and "our" refer to i-Realise Limited. We provide services to businesses and their employees. For more information about us, see Section 13.
  2. Credit
    1. This document was created using a template from SEQ Legal (https://seqlegal.com).
  3. How we use your personal data
    1. In this Section 3 we have set out:
      • the general categories of personal data that we may process;
      • the purposes for which we may process personal data; and
      • the legal bases of the processing.
    2. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and identifying how you found our site. The legal basis for this processing is our legitimate interests, namely monitoring our website, improving the relevance of its content and how effectively traffic is being driven through campaigns.
    3. We may process your account data ("account data").The account data may include your name, job title, business email address and telephone number. The account data may be processed maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent to communication OR our legitimate interests, namely the proper administration of our business and the performance of a contract (or negotiation of one) between you and us.
    4. We may process your personal data that are provided in the course of the delivery of our services ("service data"). The service data may include your name, job title, business email and telephone number and any information about your business or role which you provide to use in a telephone call or by email. The source of the service data is you or your employer. The service data may be processed for the purposes of providing our services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
    5. We may process information that you post for publication on our website or through our marketing ("publication data"). The publication data may be processed for the purposes of enabling such publication to promote our services. The legal basis for this processing is consent. You are the source of this data.
    6. We may process information contained in any enquiry you submit to us regarding our services ("enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you in line with your enquiry. The legal basis for this processing is legitimate interests, namely our interest in the proper administration of our business and communication with you.
    7. We may process information relating to transactions, including purchases of services, that you enter into with us ("transaction data”). The transaction data may include your contact details, your company’s bank details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and our legitimate interests, namely our interest in the proper administration of our business.
    8. We may process information that you provide to us for the purpose of subscribing to our email notifications, papers, podcasts and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent and the performance of a contract between you and us. You can unsubscribe at any point by emailing clovett@i-realise.co.uk
    9. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with users.
    10. We may process date relating to your customers, employees or suppliers, where you provide that to us. We will use this data to undertake surveys on behalf of your Company and to collect feedback about your service, brand, processes and ways of working. The legal basis for this processing is the performance of a contract between you and us.
    11. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
    12. We may process any of your personal data identified in this policy where necessary for [the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
    13. In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
    14. Please do not supply any other person's personal data to us, unless we prompt you to do so.
  4. Providing your personal data to others
    1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
    2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
    3. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
  5. International transfers of your personal data
    1. In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
    2. We have clients in the United States of America. The European Commission has made an "adequacy decision" with respect to the data protection laws of this country. Transfers of data provided by and to clients will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
    3. The hosting facilities for our website are situated in the UK.
    4. i-Realise Associates are situated in the United States of America. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of this country. Transfers of data provided by and to clients will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
    5. You acknowledge that personal data that you submit for publication through our website or services (such as a comment on an article or review of our services) may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
  6. Retaining and deleting personal data
    1. This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
    2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
    3. We will retain your personal data as follows:
      • All data relating to the delivery of contracted services (or discussions relating to entering into a contract with us) will be retained for a minimum period of 7 years and for a maximum period of 20 years after we last provided contracted services to you. This includes data relating to your company, employees and also your customers (where you have asked us to contact them to research their views on your company and your services).
      • Personal and contact data for marketing purposes will be retained for a minimum period of 2 years and a maximum period of 10 years. After this period, consent will need to be renewed or the data destroyed.
    4. Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  7. Amendments
    1. We may update this policy from time to time by publishing a new version on our website.
    2. You should check this page occasionally to ensure you are happy with any changes to this policy.
    3. We may notify you of changes to this policy by email.
  8. Your rights
    1. In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
    2. Your principal rights under data protection law are:
      • the right to access;
      • the right to rectification;
      • the right to erasure;
      • the right to restrict processing;
      • the right to object to processing;
      • the right to data portability;
      • the right to complain to a supervisory authority; and
      • the right to withdraw consent.
    3. You have the right to ask whether or not we process your personal data and, where we do, give you access to personal data, together with certain additional information. You may instruct us to provide you with any personal information we hold about you by emailing amann@i-realise.co.uk Provision of such information will be subject to:
      1. a payment of an admin fee (currently fixed at GBP 10); and
      2. the supply of appropriate evidence of your identity.
    4. We may withhold personal information that you request only to the extent permitted by law.
    5. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
    6. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure which includes where processing is necessary for exercising the right of freedom of expression and information; for compliance with legal obligation; or for the establishment, exercise or defence of legal claims.
    7. You may instruct us at any time not to process your personal information for marketing purposes. In practice, you will usually either expressly agreed in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes (where you are in a corporation). You can opt out by emailing clovett@i-realise.co.uk
    8. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
    9. Withdrawal of consent to process your data will not affect the lawfulness of processing before the withdrawal.
  9. About cookies
    1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
    2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Our site uses both.
    3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
  10. Cookies that we use
    1. We use cookies for the following purposes:
      • analysis - we use cookies to help us to analyse the use and performance of our website and services including how you got to our site and whether you clicked on any of our internet advertising
      • cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally (whether you consented to the use of cookies on our site) See 12 below.
  11. Cookies used by our service providers
    • Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
    • We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/ .
    • We use LinkedIn to promote our services and content from our site. This service uses cookies to track the effectiveness of this advertising to drive people to our website. You can view the privacy policy of this service provider at https://linkedin.com/legal/privacy-policy.
    • We use Twitter to promote our services and content from our site. This service uses cookies to track the effectiveness of this advertising to drive people to our website. You can view the privacy policy of this services at https://twitter.com/en/privacy
  12. Managing cookies
    1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
      • https://support.google.com/chrome/answer/95647?hl=en (Chrome);
      • https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
      • http://www.opera.com/help/tutorials/security/cookies/ (Opera);
      • https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
      • https://support.apple.com/kb/PH21411 (Safari); and
      • https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
    2. Blocking all cookies will have a negative impact upon the usability of many websites and if you block cookies, you will not be able to use all the features on our website.
  13. Our details
    1. This website is owned and operated by i-Realise Ltd.
    2. We are registered in England and Wales under registration number 05319091, and our registered office is at 1st Floor, 24/25 New Bond Street, Mayfair, London, W1S 2RR.
    3. Our principal place of business is at 6-9 The Square, Stockley Park, Uxbridge, UB11 1FW.
    4. You can contact us:
      • By post, to the postal address given above;
      • Using our website contact form - http://www.i-realise.co.uk/contact-us/;
      • By email – info@i-realise.co.uk
  14. Data protection officer
    1. Our data protection officer's contact details are: Anita Mann, Office Manager. Email: amann@i-realise.co.uk

i-Realise Limited Privacy Policy June 2018