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 tells how we look after and use your personal data when you visit our website (regardless of where you visit it from) and also tells you about your privacy rights and how the law protects you.
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 for 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) responsible for overseeing questions about 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 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, 522-524 Fulham Road, Fulham Broadway, London, SW6 5NR
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 2nd August 2023. Historical 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 provide us with 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, additional 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 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 your Submitted and Usage Information to form a view on what we think you may want or need or what may interest 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 companies.
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 due to 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 ensure 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 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 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 whom we engage to provide services to us, as follows:
- we engage with third parties called Salesforce and Hubspot to store your personal data on our behalf securely. Both third parties are American cloud computing companies which have headquarters in the US but have global offices, details of which can be found in the Where We Store Your Personal Data section of this policy.; 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 treat it according to 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:
- if 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 to comply with any legal or regulatory obligation or request; and/or
- to protect the rights, property, or safety of Imparta Limited, our customers, or others. This includes exchanging information with other companies and organizations for 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 to satisfy 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 unauthorized 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 we hold about you, we will do so within one month of receiving your request. After considering the complexity and the number of requests, we may need to extend that timeframe by two additional months. If we find your data 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 cloud-based customer relationship management platforms. Salesforce and HubSpot, both of which are sales and marketing service applications. Salesforce is 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/
HubSpot, Inc. (www.hubspot.com) is an American developer and marketer of software products for inbound marketing, sales, and customer service, founded in 2006. HubSpot has its headquarters in Massachusetts but has global offices. Full details can be found here: https://www.hubspot.com/company/contact.
Since Salesforce and HubSpot have 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 or HubSpot, 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 and HubSpot require 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”;
- if none of the above applies, we may use specific contractual clauses 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 outside the EEA who work for Salesforce or HubSpot. These staff may be engaged in the processing of your data and the provision of the services which Salesforce or HubSpot provide 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 get in touch with us.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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. However, we may need to verify the accuracy of your new data.
Request the 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 that makes you want to object to processing on this ground as you feel it impacts 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 a third party. We will provide 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 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 be unable to provide you with certain products or services. We will advise you if this is the case when you withdraw your consent.
If you wish to exercise any of the rights set out above, please get in touch with the DPO as follows: The Data Controller, Imparta Ltd, 522-524 Fulham Road, Fulham Broadway, London, SW6 5NR or by email to DataRequests@imparta.com.
No fee is 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 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 security measure provides that personal data is not disclosed to anyone with no right to receive it. We may also contact you to ask you for further information about 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 several requests. In this case, we will notify you and keep you updated.
If you wish to complain about how we have handled your personal data, you can contact our Data Protection Officer, who will investigate the matter.
If you are dissatisfied 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).