May 24, 2018
For the purposes of this document, “Group Company” or the “Company” means the Company and any holding company or any parent company or any subsidiary or fellow subsidiary undertaking of the Company or such companies, as such terms are defined in s1159, s1162 (together with Schedule 7 and the definition of “parent company” in s1173), s1161 and Schedule 6 of the Companies Act 2006, and “Group Company” means any of them.
We use your data to provide and improve our services. By visiting this site and using our services, you agree to the collection and use of information in accordance with this policy.
“Personal Data” means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
“Usage Data” is data collected automatically either generated by the use of a service or from the service infrastructure itself (for example, the duration of a page visit).
“Cookies” are small pieces of data stored on your device (computer or mobile device).
“Data Processor” (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
“Data Subject” (or user) is any living individual who is using our service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our service to you.
Types of Data Collected
The personal data we collect depends on whether you just visit our site(s) or use our services. If you visit our website, you do not need to provide any personal data. However, your browser may transmit some data automatically, such as the date and time of retrieval of our web pages, your browser types and settings, your operating systems, the last web page you visited, data transmitted and the access status, and your IP address.
We collect the following personal data in the course of offering services when you provide it to us:
- Personal details: nickname(s); given name(s); contact details (including email address; telephone number; address); and
- Electronic identifying data: including cookies; online identifier; web forms; IP addresses; activity logs; unique device identifiers and geo-location data.
Some of this personal data may be necessary for us to provide our services or perform our contract with you. Where you don’t provide us with certain personal data we may be unable to provide you or your organisation with the services requested.
If you use our services, certain personal data is required to fulfil the requirements of a contractual or service relationship, which may exist between you and us.
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We may also collect information on how our service or website is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (IP address), browser type, browser version, the pages of our site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our services.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
Use of Data
We use the collected data for various purposes:
- To provide and maintain our services;
- To notify you about changes to our services;
- To allow you to participate in interactive features of our services when you choose to do so;
- To provide customer support;
- To gather analysis or valuable information so that we can improve our services;
- To monitor the usage of our services;
- To detect, prevent and address technical issues; and
- To provide you with news, annual reports, business updates, events, communications on behalf of clients, personal introductions, product news, sector news, service news, thought leadership and general information about other services and events which we offer that are similar to those that you have already subscribed to or enquired about unless you have opted not to receive such information.
Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
We may process your Personal Data because:
- We need to perform a contract with you;
- You have given us permission to do so;
- The processing is in our legitimate interests and it’s not overridden by your rights; or
- To comply with the law.
Retention of Data
We will also retain Usage Data for internal analytic purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve our services, or we are legally obligated to retain this data for longer time periods.
Transfer of Data
Your information, including Personal Data, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside the European Union and choose to provide information to us, please note that we transfer the data, including Personal Data, to the European Union and process it there.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
We may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation;
- To protect and defend the rights or property of the Company;
- To prevent or investigate possible wrongdoing in connection with the service;
- To protect the personal safety of users of the service or the public; or
- To protect against legal liability.
Security of Data
The security of your data is important to us but remember that no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our services (“Service Providers”), to provide services on our behalf, to perform service-related services or to assist us in analysing how our service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyse the use of our services.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child(ren) has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Effective date: May 24, 2018
- By email: email@example.com
- By mail: 65 Gresham Street, London EC2V 7NQ
We have appointed IT Governance Europe Limited to act as our EU representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), or have any queries in relation to your rights or general privacy matters, please email our Representative at firstname.lastname@example.org.
Please ensure to include reference to Instinctif Partners in any correspondence you send to our representative.