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Privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and a summary of those changes will be reflected in the policy history box below.


Policy History

04/05/18

First release of this policy to include requirements in support the general data protection regulations.


1. Who we are and the Purpose of this Privacy Notice

In2itive Business Solutions Ltd ( “In2itive”, “we”, “us”, “our”) is a limited liability company registered in England and Wales. We are also registered with the Information Commissioners Office (ICO) We work in the broad field of learning technologies and we design and operate software based learning platforms that facilitate online learning and collaboration.

Purpose of this privacy notice

We are committed to respecting and protecting your privacy and this Privacy Policy (“policy”) sets out the basis on which any personal information that you provide to us will be managed or processed by us.

This website

This privacy notice aims to give you information on how we collect and processes your personal data through your use of this website, including any personal information that you may provide to us via this website when you use the contact us forms. In this case In2itive is both the Data Controller and the Data Processor.

Other websites

In2itive design learning platform websites that we then operate as a hosted online service on behalf of other organisations. If you are a user of such a learning platform website then in this scenario In2itive acts only as the Data Processor. In such cases, the organisation that owns and operates the learning platform website will be the Data Controller and their details will be clearly identifiable on their learning platform website. That organisation’s own privacy policy will be visible on their learning platform website (usually at the bottom of the web page). Their privacy policy will also contain the contact details for their organisations data protection officer (or similar title).

Data Controller at In2itive – who to contact

The data controller of this site (www.in2itive.co.uk) is In2itive Business Solutions Limited and we have a Data Protection Officer 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 Data Protection Officer at data@in2itive.co.uk or please write to The Data Protection Officer, In2itive Business Solutions Limited, In2itive Park, Holme Road, Yaxley, Cambridgeshire PE7 3NA. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO). The ICO is the UK supervisory authority for data protection issues ( www.ico.org.uk ). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on the date shown at the top of this page in the Policy History table. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name last name.
  • Contact Data includes email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address 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.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and also your communication preferences.
  • Professional Data includes any information we may collect in the course of providing our services to you.

We also collect and use Aggregated Data such as statistical or demographic data for internal purposes.

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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract that we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with an answer to an enquiry). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • You may give us your Identity Data, Contact Data, Marketing and Communications Data and Professional Data by providing it to our employees in meetings, filling in forms or by corresponding with us by phone, email, post, fax or SMS. This includes personal data you provide when you:
    • volunteer it to us in the course of using our services;
    • submit an enquiry; or
    • request literature or other marketing materials to be sent to you.
  • You may give us your Identity Data, Contact Data, Marketing and Communications Data and Professional Data by providing it to our employees in meetings, filling in forms or by corresponding with us by phone, email, post, fax or SMS. This includes personal data you provide when you:
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy for further details.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • to make contact with you for the first time (for example, where you have made an enquiry to our offices);
  • where we need to perform the contract we are about to enter into or have entered into with you;
  • 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; and
  • where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways in which we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.


Purpose/Activity

To respond to your enquiry submitted via this website, at offices or via telephone phone, email, post or SMS.

Type of data

(a) Identity
(b) Contact
(c) Professional

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you; or

(b) Necessary for our legitimate interests where you have made contact with us relating to an enquiry or prior to entering into a contractual relationship with us.


To administer and protect our business and this website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.

(a) Identity
(b) Contact
(c) Technical

(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud.

(b) Necessary to comply with a legal obligation


To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

Necessary for our legitimate interests in order to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.


To make suggestions and recommendations to you about services that may be of interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Marketing and Communications
(e) Professional

Necessary for our legitimate interests to develop our products/services and grow our business.


To provide our professional services to you

(a) Identity
(b) Professional

Performance of a contract with you


We may have to share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

Marketing

We may use your Identity, Contact, Technical and Marketing of Communications Data 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 services and offers may be relevant for you.

You may receive marketing communications from us, but only if you have requested this from us. You may ask us to stop sending you marketing messages at any time by contacting us.

Cookies

Cookies are small text files that are transferred by a website to your Internet browser directory. They help the website identify your browser or device.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

This website does not store any information that would, on its own, allow us to identify individual users of this service without their permission. Any cookies that may be used by this website are used either solely on a per session basis or to maintain user preferences. Cookies are not shared with any third parties.

Google Analytics cookies used to gather information about users for analytical purposes. This information might be how you found and navigated to our website, as well as facts about which browsers you have used. The data gathered by this cookie is anonymous and is used to enhance the usability of our website. Further information is available at Google support click here

If you wish to opt-out of being tracked by Google analytics then Google provide details on this here https://tools.google.com/dlpage/gaoptout

Change of purpose

We will only use your personal data for the purposes for which we collected it.

5. International data transfers

We do not transfer your personal data outside of the European Economic Area (“EEA”).

6. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees and contractors 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.

7. Data retention - how long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil 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 retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting The Data Protection Officer at data@in2itive.co.uk or please write to The Data Protection Officer, In2itive Business Solutions Limited, In2itive Park, Holme Road, Yaxley, Cambridgeshire PE7 3NA.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Your rights

  • 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.

Exercising your rights

If you wish to exercise any of the rights set out above, please contact The Data Protection Officer at data@in2itive.co.uk or please write to The Data Protection Officer, In2itive Business Solutions Limited, In2itive Park, Holme Road, Yaxley, Cambridgeshire PE7 3NA.

You will not have to pay a fee to access your personal data or to exercise any of the other rights. We may however 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 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.

How long will take to respond to you

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.