Welcome to Imparta’s privacy notice. Imparta Ltd is committed to protecting your personal information. It’s your information, it’s personal, and we respect that. This privacy notice will inform you as to how we look after and use your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
- Important information and who we are
- The data we collect about you, and how we collect it
- How we will use your personal data
- Who sees your personal data
- Data retention – how long will you use my personal data for?
- Where we store your personal data
- Your legal rights
Important information and who we are
This privacy notice sets out how we collect and process your personal data through your use of our website; including any data you may provide through this website when you sign up to our newsletter, or purchase a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing your personal data, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
We are Imparta Ltd and our contact details are set out below.
Who is your data controller?
A data controller is the person who determines how your personal data will be processed. Imparta Ltd is the data controller of your personal data that we collect when you visit or use this website.
Our data protection officer
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full details are:
Full name of legal entity: Imparta Ltd
Name of Data Protection Officer: Mark Abell
Email address: DataRequests@imparta.com
Postal address: Imparta ltd, 14-16 Peterborough Road, London SW6 3BN
Telephone number: +44 (0) 207 610 8800
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 (www.ico.org.uk).
Changes to this privacy notice
This version was last updated on 11 May 2018. Historic versions are archived and can be obtained by contacting us.
The data we collect about you, and how we collect it
We collect and process the following personal data about you on this website:
- Information you give us (‘Submitted Information’): you may give us information about yourself by filling in contact or other forms on this website. The information you give us may include your name, address, email address, username, password, other registration information as may be required (for example company you work for and your job title) and phone number.
- Information about your use of the website (‘Usage Information’): while using the website we will collect information on your interaction with the site, time spent on the site, the type of device you used to access the site, content views, logins, client IP address and other details provided by your connecting software.
How we will use your personal data
We will only use your personal data when the law allows us to. We will use your personal data in the following ways:
- Submitted Information: we use your Submitted Information in order to manage our relationships with you and provide you with the information, communications or services you request. We do not use this information for any other purposes. The lawful basis we rely on to process this data is our legitimate interest in promoting our business and services.
- Usage Information: we use this information for the effective administration of the website, and to deliver the content and services provided by the website. We will also use data analytics to improve our website, marketing, customer relationships and experiences. The lawful basis we rely on to process this data is our legitimate interest to develop and improve our products and services.
We may also use both your Submitted and Usage Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. We use this information to send marketing communications to you by post, telephone, or email; provided in each case that you have not opted out of receiving it. The lawful basis we rely on to process your Submitted and Usage Information for this purpose is our legitimate interest in promoting our business and services to other businesses.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. When you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions, and our use of it to provide you with our services communications.
Where we rely on our legitimate interests to process your personal data, we make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Change of purpose
We will only use your personal data 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 data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Who sees your personal data?
We may disclose some or all of your personal data to the following people:
- those of our employees and employees of our group companies who are directly involved in administering the website or your data;
- our group companies, Imparta USA and Imparta Asia Pacific;
- third parties who we engage to provide services to us, as follows:
- we engage a third party called Salesforce to securely store your personal data on our behalf. Salesforce is an American cloud computing company which has its headquarters in San Francisco but which has global offices, details of which can be found here: https://www.salesforce.com/uk/company/locations/; and
- we sometimes engage database administrators to perform administrative and development functions on our behalf.
We require all the third parties we engage with to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may disclose your personal information to other third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if Imparta Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it will be one of the assets that the third party will acquire;
- if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; and/or
- in order to protect the rights, property or safety of Imparta Limited, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We do not disclose your email address or other personal information to any third party for the purpose of enabling it to contact you for marketing purposes.
Data retention – how long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for; including for the purposes of satisfying any legal, accounting, or reporting requirements.
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.
Details of our retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. If you ask us to delete the personal information that we hold about you, we will do so within one month of our receipt of your request. We might need to extend that timeframe by two additional Months, when necessary, considering the complexity and the number of requests. If we find that your data is inaccurate (for example if your email address is no longer operational) we will also delete your data.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Where We Store Your Personal Data
We store your Submitted Information on a cloud based customer relationship management platform called SalesForce and on Pardot, which is a marketing service application. Both SalesForce and Pardot are owned and hosted by an American cloud computing company called Salesforce (www.salesforce.com). Salesforce has its headquarters in San Francisco but has global offices, details of which can be found here: https://www.salesforce.com/uk/company/locations/
Since Salesforce has offices and servers which are sometimes based outside of the EEA, their processing of your personal data on our behalf may involve a transfer of your personal data outside of the EEA. Whenever we transfer your personal data to Salesforce and that transfer involves your personal data being transferred outside of the EEA, we ensure a similar degree of protection is afforded to your personal data by ensuring that at least one of the following safeguards is implemented:
- your personal data will be transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- your personal data is protected by the fact that Salesforce requires certain members of its group of companies who are outside of the EEA to follow the same rules when processing your personal data on our behalf as those members of its group of companies who are based within the EEA. These rules are called “binding corporate rules”;
- where your personal data is transferred to members of the Salesforce group of companies who are based in the US and are part of the EU-US Privacy Shield, those members will be required to give similar protection to your personal data which we are required to give in the EEA; and
- if none of the above apply, we may use specific contractual clauses which have been approved by the European Commission which give personal data the same protection it has in the EEA.
Your data may also be processed by staff operating outside the EEA who work for Salesforce. These staff may be engaged in the processing of your data and the provision of the services which Salesforce provide to us.
If you would like further information about where your personal data might be transferred to or how we take steps to protect it, please contact us.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact the DPO as follows: The Data Controller, Imparta Ltd, 14-16 Peterborough Road, London, SW6 3BN or by email to DataRequests@imparta.com.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of your other legal rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these 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 your personal data (or to exercise any of your other legal rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.
If you are not satisfied with our response, or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO).
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.