Privacy Policy

Introduction

Individual Protection Solutions Ltd (IPS) is committed to ensuring the protection and privacy of the personal data you share with us as an IPS member.

This privacy policy will inform you as to how we look after your personal data when you visit our website.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

• Important information and who we are
• What data?
• How we use your personal data
• On what legal basis do we process personal data?
• Data security
• How long will we keep the data?
• Under what circumstances will we disclose your personal data?
• International Transfers
• Cookies
• How We Use Cookies
• How do we analyse and enhance your data?
• Automated Decision Making
• Know your rights

Important information and who we are

This privacy policy aims to give you information on how Individual Protection Solutions Ltd collects and processes your personal data through your use of this website, including any data you may provide when you sign up for IPS membership, purchase a subscription, service or digital content or take part in or contribute to any interactive features on our website.

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 policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

For the data you share with us, IPS will act as the data controller.

IPS’s Information Commissioner’s Office Registration Number is ZA279031.

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights
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If you have any questions about this privacy policy or our privacy practices, please contact our Data Privacy Manager:

• Full name of legal entity: Individual Protection Solutions Ltd (registered in England under company number 10764140).
• Email address: hello@ipscommunity.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.

What data?

Personal data, or personal information, 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, website username, password, age range.
• Contact Data includes address, email address and telephone numbers.
• Financial Data includes payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased or subscribed from us.
• Technical Data includes your login data, browser type and version, operating system and platform.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• 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 your communication preferences, history of sent emails / live chats / campaigns.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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 will ask you to set up a Username and Password to access some subscriber only information and services on our website. You should treat these like all similar information and not reveal them to others.

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

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• order or apply for our products or services;
• create an account on our website;
• subscribe to our services or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact 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. Please see the Cookie section for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below
• Technical Data from the following parties:

• analytics providers such as Amazon AWS and Google based outside the UK;

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe (based in the USA and the Republic of Ireland)

How we use your personal data

If you ask us to, your personal data will be processed in order to register your details with the Telephone Preference Service, Mailing Preference Service and other services designed to reduce your exposure to fraud, unwanted direct marketing and/or reduce paper usage. We will not register your details to any service or subscribe you to any solution without your permission.

When you become an IPS member and request services, policies or products from us or our partners, we need to collect certain information about you to process your request. Also, when you contact us, in any way, we may update your personal information or membership records. This will allow us to provide you with a higher level of service.

We have set out below, in a table format, a description of all the ways we plan to 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.

Note that 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.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile 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 products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

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.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

On what legal basis do we process 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:

• 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.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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, 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.

How long will we keep the data?

You are given the option to opt out of each part of your membership, or your IPS membership as a whole, at any time. If an opt Out request is issued to hello@ipscommunity.co.uk we will action it within 14 days.

You have the option to opt Out any or all of;

• Telephone Preference Service (through 3rd party).
• Mail Preference Service (through 3rd party).
• IPS Membership and any associated services or subscriptions.

If you have had no interaction with the IPS for 24 months we will remove your data from our system.
An interaction is defined as;

• SMS reply/click.
• Email reply/click/open.
• Use of an IPS service or subscription.
• Website account login.

However, transaction data and records of paid for services and subscriptions will be retained for 6 years, in line with IPS’s legal obligations.

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 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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see Know Your Rights below for further information.

In some circumstances we will anonymise 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.

Under what circumstances will we disclose your personal data?

There are certain circumstances where we will need to disclose your personal information to a third party, these include:

• To register you with the Telephone Preference Service; To register you with the Mail Preference Service;

• To fulfil your request to be introduced to IPS partners who will supply the services/products/policies that you have specifically requested;

• If the law permits or requires us to, or if any regulatory or governmental body requests or requires us to, even if you have not consented;

• To 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 Policy.
• Service providers, acting as processors, based in the UK who provide IT and system administration services.
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.

International Transfers

• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

1. Stripe, which processes payment details, hosts its data solely in the AWS data centres in the US. Stripe has committed to staying compliant at all times and to continuously assessing the complex landscape on data transfers in the event anything changes on requirements to localise. You can find additional information on the data transfers in Stripe’s Privacy Centre: https://stripe.com/privacy-center/legal#data-transfers

2. Zoho, which provides customer relationship management systems, uses an EU location for IPS’s data centre which means that all data is held in The Netherlands with backups in the Republic of Ireland. See https://www.zoho.com/en-uk/privacy.html

Cookies

We use cookies and similar technologies, such as ‘tags’ and ‘pixels’, to understand and improve your customer experience as you use our website and to provide you with relevant content. This section provides more information about cookies, including how we use them and how you can exercise your choices about our use of cookies

How We Use Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

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.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our 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.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the information displayed on it more relevant to your interests.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

We do not share the information collected by the cookies with any third parties.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Except for essential cookies, all cookies will expire as detailed in the table above.

How do we analyse and enhance your data?

In order to ensure that we are able to match your profile and areas of interests most accurately to our selected business partners, we will assess and analyse the personal data you share with us. This may include both;

• The use of third parties to analyse and segment IPS members’ personal data.
• Matching and augmenting the data we hold with data that has been collected by third parties.

This may result in different partner offers and services being made available to different IPS members groups or segments according to their data profile.

At all times we will ensure that any third parties handle and process your data in a secure and compliant manner. We will ensure that any third parties’ data used to match or augment the data you have shared has been obtained and processed by the third party in an open and compliant manner. Other than for these purposes we will never pass your personal data to any third parties without your express permission.

Automated Decision Making

As you share more data with us, we will start to use automated decision making techniques in order to make accurate assessments of your profile and potential needs. Thus we will be able to continue to – with your consent – present you with partner offers and services we think will be of value or interest. If you are not happy with this, or any other aspect of our processing of your data, please let us know at hello@ipscommunity.co.uk.

Know your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data (as set out below).

• 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.

• 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.

• 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.

In particular, 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, 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:

• • 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.

This Privacy Policy will be updated from time to time. This version is dated May 2021.