Inemmo Ltd – Privacy policy

Introduction

Inemmo Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.inemmo.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy and Cookie Policy is required when you first use Our Site and you should read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this policy, the following terms shall have the following meanings:

2. Information about us

1.       Our Site is owned and operated by the Inemmo Limited.
2.      Our Data Protection Officer is Daniel Jacobs, and can be contacted by email at da****@In****.com  by telephone on 0800 689 9110

1. What does this policy cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

3. Your rights

1. As a data subject, you have the following rights under the GDPR, which this Policy and Our use of Personal Data have been designed to uphold:

1.      The right to be informed about Our collection and use of Personal Data;

2.      The right of access to the Personal Data We hold about you (see section 12);

3.     The right to rectification if any Personal Data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);

4.      The right to be forgotten – i.e. the right to ask Us to delete any Personal Data We hold about you (We only hold your Personal Data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);

5.     The right to restrict (i.e. prevent) the processing of your Personal Data;

6.     The right to data portability (obtaining a copy of your Personal Data to re-use with another service or organisation);

7.      The right to object to Us using your Personal Data for particular purposes; and

8.     Rights with respect to automated decision making and profiling.

   2. If you have any cause for complaint about Our use of your Personal Data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

  3. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

4. What data do we collect?

Depending upon your use of Our Site, We may collect some or all of the following personal and non-Personal Data (please also see section 13 on Our use of Cookies and similar technologies.

1. Salutation;
2. name;
3. date of birth;
4. gender;
5. business/company name
6. job title;
7. profession;
8. contact information such as email addresses and telephone numbers;
9. demographic information such as post code, preferences, and interests;
10. financial information such as credit / debit card numbers;
11. IP address;
12. web browser type and version;
13. operating system;
14. a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;

5. How do we use your Data?

1.       All Personal Data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.

2.      Our use of your Personal Data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes: Providing and managing your Account;

• Providing and managing your access to Our Site;
• Personalising and tailoring your experience on Our Site;
• Supplying Our products and services to you (please note that We require your Personal Data in order to enter into a contract with you);
• Personalising and tailoring Our products and services for you;
• Replying to emails from you;
• Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time via our website          www.inemmo.com under the ‘Contact Us’ section and send us a message or email in**@in****.com
• Market research, including product usage and transactional data.

3.     With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or   telephone and text message with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.4.

4.     Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

5.     You have the right to withdraw your consent to Us using your Personal Data at any time, and to request that We delete it.

6.     We do not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the period as stated within Our Retention Policy.

6. How and Where Do We Store Your Data?

1.      We only keep your Personal Data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

2.      Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).

3.      Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

7. How and Where Do We Store Your Data?

1.     Subject to section 8.2, We will not share any of your data with any third parties for any purposes.

2.     We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

3.     We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

4.     We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any Personal Data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.

5.     In certain circumstances, We may be legally required to share certain data held by Us, which may include your Personal Data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

8. What Happens If Our Business Changes Hands?

1.     We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any Personal Data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

2.     In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.

9. How Can You Control Your Data?

1.     In addition to your rights under the GDPR, set out in section 4, when you submit Personal Data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).

2.     You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

10. Your right to withhold information

1.     You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

2.     You may restrict Our use of Cookies. For more information, see section 13

11. How can you access your Data?

You have the right to ask for a copy of any of your Personal Data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at gd**@In***********.com, or using the contact details below in section 14.

12. Our use of Cookies

Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.

What are Cookies?

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device. You can find more information about cookies by visiting:

www.allaboutcookies.org.;      or     www.aboutcookies.org

How the Inemmo Limited Uses Cookies

Cookies allow the Inemmo to recognise devices and track how our visitors use inemmo.com. We use cookies that are essential for you to navigate inemmo.com or provide you with basic website features. Data collected from some cookies helps us enhance the performance of inemmo.com and offer you a better user experience. We will not use any of this data to identify you personally, it is used only to monitor and improve inemmo.com.There are several types of cookies that are used to keep track of information needed by a site user as they travel from page to page within a website..

Cookies on Inemmo Limited Sites and Microsites First-party cookies

Cookies can be used to track internet activity after the user has left a website. These are normally facilitated by organisations external to the website being visited and are generally known as ‘third-party’ cookies. They usually have a long lifetime with several months being quite common. They are ‘harvested’ and ‘refreshed’ whenever the user visits a page where the same or a similar cookie is being used.

Third-party cookies and microsites

The domain specified in the cookie relates to the cookie’s owner (the “party”), who has set the cookie. inemmo.comcookies will have the inemmo.comdomain specified in a cookie.

These are first-party cookies. inemmo.comsets a number of cookies. These are used to analyse visitors’ browsing of inemmo.comfor future improvements and to provide certain useful functions such as storing your login details, if you are an Inemmo Limited member.

The data is not used to identify individual members. A third-party cookie is set when you visit a site but the domain named in the cookie sent to your computer is not the same as the website. For example, if you visit inemmo.com.com, you may visit the

Other Third Party processing activities

If you shorten our site URLs, for example on Twitter or Facebook, we may use services such as goo.gl, bit.ly, tinyurl.com and ow.ly to do so, and our site works with these to rebrand our URLs as a https://inemmo.com.com/xxxxx link. Also our website sometimes offers features that allow users to share links with social networks and our site may shorten that URL using one of these services.

If you shorten our site URLs, for example on Twitter or Facebook, we may use services such as goo.gl, bit.ly, tinyurl.com and ow.ly to do so, and our site works with these to rebrand our URLs as a https://inemmo.com.com/xxxxx link. Also our website sometimes offers features that allow users to share links with social networks and our site may shorten that URL using one of these services.These services provide us with anonymised, aggregated statistics relating to the use of our shortened URL, for example by telling us how many times it has been clicked on. We do not have access to the IP address of your computer collected by these services or any other identifiable information about you. Nor do they have any access to data collected on our website.For more information on these services please see below:

•     Google urlshortener, goo.gl – Privacy policy
•     Bitly Enterprise, bit.ly – Privacy policy
•     TinyURL, tinyurl.com – Terms of use
•     Ow.ly urlshortener, ow.ly

Google Analytics

We currently use Google Analytics to measure and analyse visitor information related to our web site. For that purpose, your IP address, internet traffic data and data on your browser type and PC are collected using several cookies (_utma, _utmc, utmb, utmz):

•          _utma is used by Google Analytics to identify first-time site (‘unique’) visitors vs. returning visitors. It expires after two years

•          _utmz tracks source visits (the origin of the visit). It expires after six months.

•          _utmc identifies unique visitors vs. returning visitors but expires when you close your browser.

•          _utmb is used for general visitor tracking and expires after 30 minutes.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. For information on how to reject or delete this cookie.

Please visit https://www.google.com/intl/en/privacypolicy.html for more information.

Google Analytics

Microsites are collections of webpages created as a discrete entity within a larger website. Microsite pages are usually related by content on a similar topic. They often have a different domain name from the parent website and content for microsites may be provided by specialist organisations.

inemmo.com hosts several microsites on our servers and links to many others hosted by our corporate partners. Inemmo does not control dissemination of third party cookies.

14. Contacting us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at da****@in****.com, or by telephone on 0800 689 9110. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above)

15. Changes to our Privacy Policy

1.      We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.1. We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

2.      For the avoidance of doubt all policies relating to GDPR and/or data protection (whether referred to on the infonet, the Inemmo Limited website or otherwise communicated to the Inemmo Limited’s staff, members or non-members) are not contractually binding on the Inemmo Limited and may be withdrawn or amended at any time. They will be under ongoing review and will be replaced with the latest versions accordingly.