We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
This version was last updated on 15/02/2018 and historic versions can be obtained by contacting us.
Important Information and Who We are
Insiris Limited is the controller and responsible for your personal data (collectively referred to as “Insiris”, "we", "us" or "our" in this privacy notice).
Our full details are:
Full name of legal entity: Insiris Limited
Email address: firstname.lastname@example.org
Postal address: 2nd Floor Derby House, Winckley Square, Preston PR1 3JJ
Telephone number: +44 (0)1772 977 297
The Data we collect about you
What is Personal 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 act as a data controller where you download our mobile application, or visit our websites prior to logging in as an Authorised User. We will also be a data controller where you contact us directly. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes name, username or similar identifier
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 our websites
Profile Data includes your username and password, and details of our customer who has authorised you to use our services
Usage Data includes information about how you use our website, mobile app and services
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law provided this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the number of users accessing a specific 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 notice.
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.
Where we are a data processor on behalf of our Customer
For the most part, we act as a data processor on behalf of our Customer (being the person who we have entered into a service licence with, and who has nominated you as an Authorised User of our Services). We may process additional types of personal data on behalf of our Customer and we do so strictly in accordance with their instructions. This Privacy Notice does not cover our actions as a data processor and you should consult their Privacy Notice to determine how they use your personal data. We cannot be responsible for their acts or omissions.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected and used?
We use different methods to collect data from and about you including through:
Visitors to our websites
When you visit our websites, we use third party services, Google Analytics, Wix and LinkedIn to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the websites. This information is only processed in a way which does not identify anyone. We do not make, and do not allow these providers to make, any attempt to find out the identities of those visiting our websites.
You may decide to submit personal information to us through the website, for example when completing the ‘Contact Us’ form. When we collect personal data in this way this policy sets out what we intend to do with it.
Our websites are not intended for children and we do not knowingly collect data relating to children.
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive.
We use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
We may collect personal information from our direct interactions with you. This may include through correspondence, attendance at meetings with you, or other direct interactions such as if you make support requests.
How long do we keep your data
We will keep your personal data for as long as you are an Authorised User of our Services, and then for a period of 6 years thereafter unless required to keep it longer by law..
Where we are processing your personal data on behalf of our Customer, we will comply with their retention periods unless required to keep any personal data longer by law.
We use Aggregated Data to develop our services and products, but we may from time to time use your personal data and other information provided by you to improve our service. This may include using recordings of calls for training purposes, and we will tell you if this is likely to be the case. You can ask for the call to not be used in this manner.
We may also use personal information that you have provided (including your communications with us) to offer customer support and fix problems.
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.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out above. These parties may be:
Our Customer who has nominated you as an Authorised User.
Service providers (acting as processors) who provide IT and system administration services and support.
Professional advisers (acting as processors or joint controllers) including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities (acting as processors or joint controllers) based in the United Kingdom who require reporting of processing activities in certain circumstances.
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.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties are based outside the European Economic Area (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.
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.
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 the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are summarised below:
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 may object to our processing of your personal data. 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 you may withdraw this consent at any time. 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.
How to exercise your rights
If you wish to exercise any of the rights set out above, please contact us. If you are submitting a data subject access request it would be helpful if you could complete a copy of our subject access request form which can be provided by contacting us. This will enable us to identify and deal with your request much more quickly.
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 may 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 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.
Your right to complain to the Information Commissioner’s Office.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), 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.