DATA PROTECTION FRAMEWORK
Full name of legal entity: Dave Draycott
Email address: firstname.lastname@example.org
Postal address: 1 Grange Court, Covent Garden, Willingham, Cambridge, CB24 5AH
Telephone number: +44 (0)1954 262000
The lawful basis we will seek to rely on to process personal information is consent given by you for one or more specific purpose as set out in Article 6 of the GDPR.
Personal data, personal information (PI) and/or personally identifiable information (PII) means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, job title, employer and title.
- Contact Data includes email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
- Usage Data includes information about how you use our Website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We use different methods to collect data from and about you including through:
- Direct interactions: You may decide to send us your personal information via this Website, for example, if you are seeking more information, requesting to attend one of our events, downloading reports, requesting a demo, joining a mailing list, subscribing to receive communications from us or for other similar purposes. Your decision to disclose your personal data is entirely voluntary, and by doing so, you are providing us with specific consent to use your personal data only for the purposes for which you have disclosed it to us.
- Automated technologies or interactions: As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the paragraph titled ‘Website Cookies’ below for our policy in relation to cookies.
- Third parties or publicly available sources: We will receive personal data about you from various third parties and public sources.
USE OF PERSONAL DATA
Imagen may access and use your personal data only for the purposes for which you have submitted it to us to (a) provide information to you, (b) make contact with you, (c) provide services to you, or (d) maintain the operations and security of this Website and services we provide to you. Except for where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, or where we need to comply with a legal obligation, we will not use your personal data for any other purposes, for example the communication of marketing material, unless we have your specific consent to do so.
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
To contact Imagen, please see our contact details below.
You can ask us or third parties to stop sending you marketing messages at any time by following the un-subscribe links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a transaction.
CUSTOMER AND CITIZEN DATA RIGHTS
As prescribed within data protection regulations, you have several rights connected to the provision of your personal data to Imagen using this Website. These include your rights 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.
restriction of processing of your personal data. This enables
you to ask us to suspend the processing of your personal data in the following
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 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 could 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.
To contact Imagen, please see our contact details below.
If Imagen does not address your request, or fails to provide you with a valid reason why it is unable to do so, you have the right to contact the Information Commissioner’s Office to make a complaint. They can be contacted via their website (www.ico.org.uk) or by telephone 0303 123 1113.
DECLARATION OF SUB-PROCESSING
We use a number of trusted data processors as part of the provision of our services to you:
Data supplied by you for the purposes of our marketing services is stored and maintained by Salesforce CRM. Salesforce CRM data security has been certified to comply with a number of international standards, including PCI DSS, FISMA, ISO/IEC 27001:2005, SAS 70 Type II, SysTrust, and Eu-US and Swiss-US Safe Harbor. Details of Salesforce security standards can be found here.
Salesforce’s commitment to data protection and GDPR compliance can be found here.
We use Hubspot for analytical and functional data capture.
We use NextRoll
- Disclosure of the purposes of processing the personal data collected on your sites (i.e. the NextRoll services which you are using);
- The legal basis you rely on to process each type of personal data (e.g. consent); and
- Identification of the entities that receive (or with whom you share) the personal data collected (i.e. NextRoll, Inc.).
SECURITY OF PERSONAL INFORMATION
We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on secure servers.
All communications via this Website, electronic documents and database records will be protected by encryption technology.
You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
STORAGE OF DATA
Personal data collected from the website may be stored in any of the following locations:
- Cookie and tracker service provider data centres;
- Salesforce Cloud Hosted CRM;
- Microsoft Cloud Outlook365 Email servers;
- Imagen internal systems and document servers.
INTERNATIONAL DATA TRANSFERS
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Our service provider certifications demonstrating compliance with the EU-US Privacy shield will be audited annually.
RETENTION OF PERSONAL DATA
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we considered 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, regulatory, tax, accounting or other requirements.
Our standard retention periods are as follows:
- All data collected from you is retained for 5 years from the date of collection.
- Communications & marketing sign-up details are retained until a request to un-subscribe is received. In accordance with Privacy & Electronic Communications Regulations 2003 and relevant ICO guidance, email communications will contain an un-subscribe link.
Cookies are small text files sent by us to your computer, or from your computer or mobile device to us each time you visit this Website. They are unique to you or your web browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them, or until they expire.
You can decline to have personal data collected via third party tracking technologies by navigating to the settings feature in your browser and declining all third party cookies or declining third party cookies from specific sites, or, for mobile, limiting ad tracking or resetting the advertiser identifier via the privacy settings on your mobile device.
You may prefer to use a third-party tool that ops out of targeted or interest based advertising. Available third-party opt-out tools include: the Digital Advertising Alliance, the Network Advertising Initiative, and the European Interactive Digital Advertising Alliance (Europe only).
This Website may include relevant hyperlinks to external websites not controlled by Imagen. Whilst all reasonable care has been exercised in selecting and providing any such links, you are advised to exercise caution before clicking any external links. We cannot guarantee the ongoing suitability of external links, nor do we continually verify the safety or security of the contents which may be provided to you. You are advised, therefore, that your use of external links is at your own risk and we cannot be responsible for any damages or consequences caused by your use of them.
1 Grange Court, Covent Garden, Willingham, Cambridge, UK CB24 5AH
You can also contact us:
- using this Website contact form
- by telephone, using the contact number published on this Website; or
- by email, using the email address published on this Website.
Version current as of 09.07.2019.