Illuminatis Limited ("We", “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the General Data Protection Regulation (“GDPR) the Data Controller is Illuminatis Limited.
YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all of the following types of information from you in the course of providing our services:
• Information that you provide in the course of communications with Us. This includes information you provide when requesting further details of Our products and services, filling in forms on our website, or when negotiating contracts for the provision of products and/or services (either where we are your customer or a supplier).
• Specifically we will process personal details such as your name, email address, telephone numbers (switchboard, direct lines and mobile numbers) and any information input by you when using the website, completing our survey forms, using our services.
• If you contact Us, We may keep a record of that correspondence.
• We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.
• Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
When using our online “Contact” form the provision of your name and email is required from you to enable Us to respond to your query. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.
Information We Collect From Other Sources
Where We contact potential customers about business opportunities, We will also obtain personal data from other sources as follows:
• Referrals from business colleagues
• Company web sites
USES MADE OF YOUR INFORMATION
Lawful basis for processing
To carry out any other obligations arising from any contracts entered into between you and Us. We rely on “performance of a contract with you” as the legal basis for this processing.
We may also rely on legitimate interest as the lawful basis on which We collect and use your personal data. Our legitimate interests are performance of contracts with our customers and suppliers, marketing and business development and the administration and improvement of our website.
Where you have contacted us via our website, e-mail and telephone, we rely on “legitimate interest” and the legitimate interest is “responding and contacting you regarding the enquiries you have made in relation to the services we offer”.
Purposes of processing
We use information held about you in the following ways:
• To provide you or the organisation that you are engaged by with our services.
• To carry out our obligations arising from any contracts entered into between you (or the organisation that you are engaged by) and Us.
• To provide you with information and offers that you request from Us or which We feel may interest you.
• To notify you about changes to our service.
• To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website;
In addition to the above uses We may use your information (to notify you about goods or services which may be of interest to you. Where We do this, We will contact you by electronic means (e-mail or SMS) only if you have consented to such communication. If you do not want Us to use your data in this way please either (i) tick the relevant box situated on the form on which We collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform Us at any time by contacting Us at the contact details set out below.
DISCLOSURE OF YOUR INFORMATION
We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers).
We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may also disclose your personal data to 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; or
• if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
• if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our [e.g. Website Terms and Conditions and other agreements]; or
• to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the Website; or
Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
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 the Website; 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.
Keeping your personal data up to date
If your personal details change you may update them by contacting Us using the contact details below.
We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
How long we keep your personal data
We will hold the data set out above for a reasonable time having regard to the nature of the personal data and the purpose for which it was collected. In particular:
• Where we hold your personal data in connection with the performance of a contract with one of our customers or suppliers, we will hold your data, and in particular any communications between you and us in relation to the negotiation or performance of the contract by either party for so long as that contract is in force and for a period of at least 10 years after;
• Where we hold your data in connection with the marketing or promotion of our business, we will hold your data for up to 5 years, or for up to 5 years after you last communicated with us, if later.
• If you contact us via our website contact form, requesting general information about our services, we will hold personal data you choose to provide such as your name, company name, email address, for 5 years from our last point of contact.
• In respect of website usage data, we hold your data for 5 years from the date of collection.
• For all data, we hold your data for 5 years.
Where we store your personal data
All information We hold about you is stored on secure servers.
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). We will take all steps reasonably necessary to ensure that your data is held securely and in accordance with this Policy. Countries outside the EEA do not have the same data protection laws as the United Kingdom and EEA and we have therefore ensured that any of our suppliers who may transfer your personal data outside the EEA has put in place appropriate measures to protect your data, either by being a member of the US-EU Privacy Shield, or by entering into a European Commission approved contract (as permitted under Article 46(5) of the General Data Protection Regulation).
We will not otherwise transfer your personal data outside the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries. If you would like further information please contact Us (see ‘Contact’ below).
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
access to your personal data and to certain other supplementary information that this Policy is already designed to address
require Us to correct any mistakes in your information which We hold
require the erasure of personal data concerning you in certain situations
receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal data concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal data
otherwise restrict our processing of your personal data in certain circumstances
claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please: email, call or write to Us let Us have enough information to identify you [(eg account number, user name, registration details)], let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and let Us know the information to which your request relates
HOW TO COMPLAIN
We hope that We can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.
A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
The cookies We use include:
• “Analytical” cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps Us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to firstname.lastname@example.org.