Privacy Policy 

We take your privacy very seriously.Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

 

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA). We are also subject to the UK General Data Protection Regulation (UK GDPR).

 

1.         Key Terms

 

It would be helpful to start by explaining some key terms used in this policy:

We, us, our: Imvizar Limited

Personal data: Any information relating to an  identified or identifiable individual

Special category personal data: Personal data revealing racial or  ethnic origin, political opinions, religious beliefs, philosophical beliefs  or trade union membership; Genetic and biometric data (when  processed to uniquely identify an individual); Data concerning health, sex life or  sexual orientation

Data subject: The individual who the personal data  relates to

 

 

2.         Personal Data We Collect About You

 

We may collect and use the following personal data about you:

(i)         your name and contact information, including email address and telephone number and company details

(ii)        information to check and verify your identity, eg your date of birth

(iii)       your gender, if you choose to give this to us

(iv)       location data, if you choose to give this to us

(v)        your billing information, transaction and payment card information

(vi)       your personal or professional interests

(vii)       your professional online presence, eg LinkedIn profile

(viii)     your contact history, purchase history and saved items

(ix)       information from accounts you link to us, eg Facebook

(x)        Information about how you use our website, IT, communication and other systems

(xi)       your responses to surveys, competitions and promotions

 

We collect and use this personal data to provide products and services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing products and/or services to you.

 

3.         How Your Personal Data Is Collected

 

We collect most of this personal data directly from you either in person, by telephone, text or email and via our website and app.

 

However, we may also collect information from other sources such as: 

(i)         from cookies on our website—for more information on our use of cookies, please see our cookie policy, available on our website.

(ii)        via our IT systems e.g. through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;

 

 

4.         How and Why We Use Your Personal Data

 

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

(i)         where you have given consent;

(ii)        to comply with our legal and regulatory obligations;

(iii)       for the performance of a contract withyou or to take steps at your request before entering into a contract; or

(iv)       for our legitimate interests or those of a third party.

 

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carryout an assessment when relying on legitimate interests, to balance our interests against your own.

 

The table below explains what we use your personal data for and why.

 

What we use your personal data for - Our reasons

Providing products and services to  you - To perform our contract with you or  to take steps at your request before entering into a contract

Preventing and detecting fraud  against you or us

For our legitimate interests or those  of a third party, i.e. to minimise fraud that could be damaging for you  and/or us

Activities necessary to comply with  professional, legal and regulatory obligations that apply to our business, e.g.  under health and safety law or rules issued by our professional regulator

To comply with our legal and  regulatory obligations

Ensuring business policies are  adhered to, e.g. policies covering security and internet use

For our legitimate interests or those  of a third party, i.e. to make sure we are following our own internal  procedures so we can deliver the best service to you

Operational reasons, such as  improving efficiency, training and quality control

For our legitimate interests or those  of a third party, i.e. to be as efficient as we can so we can deliver the  best service to you at the best price

Ensuring the confidentiality of  commercially sensitive information

For our legitimate interests or those  of a third party, i.e. to protect trade secrets and other commercially  valuable information

To comply with our legal and  regulatory obligations

Statistical analysis to help us  manage our business, e.g. in relation to our financial performance, customer  base, product range or other efficiency measures

For our legitimate interests or those  of a third party, i.e. to be as efficient as we can so we can deliver the  best service to you at the best price

Preventing unauthorised access and  modifications to systems

For our legitimate interests or those  of a third party, i.e. to prevent and detect criminal activity that could be  damaging for you and/or us

To comply with our legal and  regulatory obligations

Updating and enhancing customer  records

To perform our contract with you or  to take steps at your request before entering into a contract

To comply with our legal and  regulatory obligations

For our legitimate interests or those  of a third party, e.g. making sure that we can keep in touch with our  customers about existing orders and new products

Statutory returns

To comply with our legal and  regulatory obligations

Ensuring safe working practices,  staff administration and assessments

To comply with our legal and  regulatory obligations

For our legitimate interests or those  of a third party, e.g. to make sure we are following our own internal  procedures and working efficiently so we can deliver the best service to you

Marketing our services and those of  selected third parties to:

—existing and former customers; 

—third parties who have previously  expressed an interest in our services;

—third parties with whom we have had  no previous dealings.

For our legitimate interests or those  of a third party, i.e. to promote our business to existing and former  customers

External audits and quality checks, e.g.  for ISO or Investors in People or equivalent accreditation and the audit of  our accounts

For our legitimate interests or a  those of a third party, i.e. to maintain our accreditations so we can  demonstrate we operate at the highest standards

To comply with our legal and  regulatory obligations

 

Where we processspecial category personal data, we will also ensure we are permitted to do sounder data protection laws, for example:

(i)         we have your explicit consent;

(ii)        the processing is necessary to protectyour (or someone else’s) vital interests where you are physically or legallyincapable of giving consent; or

(iii)       the processing is necessary toestablish, exercise or defend legal claims.

 

 

5.         Marketing

 

We may use yourpersonal data to send you updates (by email, text message, telephone or post)about our products and services, including exclusive offers, promotions or newproducts and services.

 

We have a legitimateinterest in using your personal data for marketing purposes (see above ‘Howand why we use your personal data’). This means we do not usually need yourconsent to send you marketing information. However, where consent is needed, wewill ask for this separately and clearly.

 

You have the right toopt out of receiving marketing communications at any time by:

(i)         contacting us at info@imvizar.com

(ii)        using the ‘unsubscribe’ link in emailsor ‘STOP’ number in texts

 

We may ask you to confirm or update your marketingpreferences if you ask us to provide further products and services inthe future, or if there are changes in the law, regulation, or the structure ofour business.

 

We will always treatyour personal data with the utmost respect and never sell OR share it withother organisations for marketing purposes.

 

6.         Who We Share Your Personal Data With

 

We routinely sharepersonal data with:

(i)         Webflow, Google, Amazon Web Service andUnity

(ii)        third parties we use to help deliverour products and services to you, e.g. payment service providers, warehousesand delivery companies;

(iii)       other third parties we use to help usrun our business, e.g. marketing agencies or website hosts;

(iv)       third parties approved by you, e.g.social media sites you choose to link your account to or third party paymentproviders;

 

We only allow ourservice providers to handle your personal data if we are satisfied they takeappropriate measures to protect your personal data. We also impose contractualobligations on service providers to ensure they can only use your personal datato provide services to us and to you. 

 

We may also need to:

(i)         share personal data with externalauditors, e.g. in relation to ISO or Investors in People accreditationand the audit of our accounts;

(ii)        disclose and exchange information withlaw enforcement agencies and regulatory bodies to comply with our legal andregulatory obligations;

(iii)       share some personal data with otherparties, such as potential buyers of some or all of our business or during arestructuring—usually, information will be anonymised but this may not alwaysbe possible, however, the recipient of the information will be bound byconfidentiality obligations.

 

If you would likemore information about who we share our data with and why, please contact us(see ‘How to contact us’ below).

 

 

7.         Where Your Personal Data is Held

 

Personal data may beheld at our offices and those of our third party agencies, service providers,representatives and agents as described above (see above: ‘Who we share yourpersonal data with’).

 

Some of these thirdparties may be based outside the EEA/UK. For more information, including on howwe safeguard your personal data when this happens, see below: ‘Transferringyour personal data out of the EEA/UK

.

8.         How Long Your Personal Data Will Be Kept

 

We will keep yourpersonal data while you have an account with us or we are providing products and/orservices to you.

 

Thereafter, we willkeep your personal data for as long as is necessary:

(i)         to respond to any questions, complaintsor claims made by you or on your behalf;

(ii)        to show that we treated you fairly;

(iii)       to keep records required by law.

 

We will not keep yourpersonal data for longer than necessary. Different retention periods apply fordifferent types of personal data.

 

When it is no longernecessary to keep your personal data, we will delete or anonymise it.

 

9.         Transferring Your Personal Data out ofthe EEA and UK

 

To deliver servicesto you, it is sometimes necessary for us to share your personal data outsidethe UK/EEA, e.g.:

(i)         with our offices or other companieswithin our group located outside the UK/EEA;

(ii)        with your and our service providerslocated outside the UK/EEA;

(iii)       if you are based outside the UK/EEA;

(iv)       where there is a European and/orinternational dimension to the services we are providing to you.

 

Under data protectionlaw, we can only transfer your personal data to a country or internationalorganisation outside the EEA/UK where:

(i)         the European Commission or the UKgovernment has decided the particular country or international organisationensures an adequate level of protection of personal data (known as an ‘adequacydecision’); 

(ii)        there are appropriate safeguards inplace, together with enforceable rights and effective legal remedies for datasubjects; or

(iii)       a specific exception applies under dataprotection law

 

These are explainedbelow.

 

Adequacy Decision

 

We may transfer your personal data to certain  countries, on the basis of an adequacy decision. These include:

(i)               all European Union countries, plus  Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);

(ii)              Gibraltar; and

(iii)             Andorra, Argentina, Canada, Faroe  Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand,  Switzerland and Uruguay.

 

The list of countries that benefit  from adequacy decisions will change from time to time. We will always seek to  rely on an adequacy decision, where one exists.

 

Other countries or international  organisations we are likely to transfer personal data to do not have the  benefit of an adequacy decision. This does not necessarily mean they provide  poor protection for personal data, but we must look at alternative grounds  for transferring the personal data, such as ensuring appropriate safeguards  are in place or relying on an exception, as explained below.

 

Transfers with Appropriate Safeguards

Where there is no adequacy decision,  we may transfer your personal data to another country or international  organisation if we are satisfied the transfer complies with data protection  law, appropriate safeguards are in place, and enforceable rights and  effective legal remedies are available for data subjects.

 

The safeguards will usually include  using legally-approved standard data protection contract clauses.

To obtain a copy of the standard data  protection contract clauses and further information about relevant safeguards,  including our binding corporate rules, please contact us (see ‘How to  contact us’ below).

 

Transfers Under an Exception

In the absence of an adequacy decision or  appropriate safeguards, we may transfer personal data to a third country or  international organisation where an exception applies under relevant data  protection law, e.g.:  

(i)               you have explicitly consented to the  proposed transfer after having been informed of the possible risks;

(ii)              the transfer is necessary for the  performance of a contract between us or to take pre-contract measures at your  request;

(iii)             the transfer is necessary for a  contract in your interests, between us and another person; or

(iv)            the transfer is necessary to  establish, exercise or defend legal claims.

 

We may also transfer information for the purpose  of our compelling legitimate interests, so long as those interests are not  overridden by your interests, rights and freedoms. Specific conditions apply  to such transfers and we will provide relevant information if and when we  seek to transfer your personal data on this ground.

 

Further information

If you would like further information  about data transferred outside the UK/EEA, please contact us (see ‘How to  contact us’ below).

 

 

 

10.       Your Rights

 

You have the following rights, which you can exercise free of charge:

 

Access

The right to be provided with a copy  of your personal data

Rectification

The right to require us to correct  any mistakes in your personal data

Erasure (also known as the right to  be forgotten)

The right to require us to delete  your personal data, in certain situations

Restriction of processing

The right to require us to restrict  processing of your personal data in certain circumstances, e.g. if you  contest the accuracy of the data

Data portability

The right to receive the personal  data you provided to us, in a structured, commonly used and machine-readable  format and/or transmit that data to a third party, in certain situations

To object

The right to object:

-       at any time to your personal data  being processed for direct marketing (including profiling);

-       in certain other situations to our  continued processing of your personal data, e.g. processing carried out for  the purpose of our legitimate interests

Not to be subject to automated  individual decision making

The right not to be subject to a decision  based solely on automated processing (including profiling) that produces  legal effects concerning you or similarly significantly affects you

For further information on each ofthose rights, including the circumstances in which they apply, please contactus (see ‘How to contact us’ below) or see the Guidance from the UKInformation Commissioner’s Office (ICO) on individuals’ rights.

 

If you would like to exercise any of those rights, please:

(i)         email, call or write to us—see below:‘How to contact us’; and

(ii)        provide enough information to identifyyourself (e.g. your full name, address and customer or matter reference number)and any additional identity information we may reasonably request from you;

(iii)       let us know what right you want toexercise and the information to which your request relates.

 

11.       Keeping your personaldata secure

 

We have appropriatesecurity measures to prevent personal data from being accidentally lost, orused or accessed unlawfully. We limit access to your personal data to those whohave a genuine business need to access it. Those processing your informationwill do so only in an authorised manner and are subject to a duty ofconfidentiality.

 

We also haveprocedures in place to deal with any suspected data security breach. We willnotify you and any applicable regulator of a suspected data security breachwhere we are legally required to do so.

 

 

12.       How to complain

 

Please contact us ifyou have any query or concern about our use of your information (see below ‘Howto contact us’). We hope we will be able to resolve any issues you mayhave.

 

You also have theright to lodge a complaint with the Information Commissioneror any relevantEuropean data protection supervisory authority. The Information Commissionermay be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303123 1113.

 

13.       Changes to thisprivacy policy

This privacy noticewas published on 10/09/21 and last updated on 22/10/21.

We may change thisprivacy notice from time to time—when we do we will inform you via our websiteor other means of contact such as email.

 

14.       How to contact us

 

Individuals in the UK

You can contact usby email if you have any questions about this privacy policy or theinformation we hold about you, to exercise a right under data protection law orto make a complaint.

 

Our contact detailsare shown below:

 

info@imvizar.com

 

Individuals in the EEA

We have appointed MichaelGuerin to be our data protection representative within the EEA. Their contactdetails are info. Individuals within the EEA can contact us direct (see above)or contact our European representative.

 

Do you need extrahelp?

Pleasecontact us at info@imvizar.com