Data NOT covered by this Privacy Notice
We provide digital learning and compliance apps to corporate clients to train their employees and associated persons, and comply with regulations. If you are an employee of one of our clients, please note that the controller of your personal data is your employer, or the company that has procured the services for you.
If this is the case, we are merely data processors and act only upon the instructions of the data controller. Under the terms of the Data Processing Agreement that we have signed with the controllers, we have provided safeguards for protecting your data, and for supporting the controllers in delivering on your rights and freedoms under the GDPR.
We do not access your data for any of our purposes, and we cannot deal with you directly on any of your requests. If you have any questions about your data, you must speak to your supervisor or compliance/learning administrators.
This privacy notice is provided to inform only the individuals whose data we hold as data controllers.
We collect and process the data of individuals on the basis of our legitimate business interests of promoting our staff compliance products and services. We believe that this is reasonably expected of us as a part of running our business, and it does not materially impact your rights, freedom or interests.
In certain situations, we may also process personal data with the consent of the individual is concerned.
How do we collect your personal data?
We may collect your personal data when you:
- Visit our website
- Contact us by email or phone
- Fill out any form for information
- Engage with us on social media
- Log into our demo portal or access any of our demo courses
We may have your data from public sources prior to 1st May 2018.
We do not collect any data from client portals managed by us.
What type of personal data do we collect?
We collect and retain the following information about you:
- Your name
- Email address
- Phone number
- Office address
- Username and Password (for accessing our demo portal and courses)
- Your interactions with us on our website, emails, demo portal
- Notes of any conversation that you have with us
- Our understanding of your buying intentions
We do not hold any personal financial information, sensitive information, or any special category data on you.
How do we use your personal data?
Where we have acquired your personal data, we are the data controllers and will use the data exclusively to interact with you to promote our products and services for your employer. We are allowed to do this as a part of our legitimate business interests as provided by Recital 47 of the GDPR.
We will only contact you on what we believe is your work email and phone number strictly in your capacity as a representative, decision-maker or influencer for your employer. We do not seek to market any services to you in your personal capacity. If you believe that we have got this wrong, please send us an email addressed to email@example.com and we will amend or delete your records as per your wishes.
Examples of how we may use your data:
- To provide you access to our demo portal and demo courses
- To process orders and service agreements for your employer
- To respond to your queries, requests and complaints
- To send you information about our products, services and updates that are meant for your employer
- To administer any contest or competitions that you have entered – based on the consent you have given at the time of entry
- To develop test and improve our products and services – which we do on the basis of our legitimate business interests
- To comply with any contractual, regulatory or legal obligations
We will never sell your data or provide it to any third party for any purpose other than what we've described above.
How do we protect your personal data?
The security of your personal data is very important to us and we take the utmost care. We have implemented appropriate technical and organisational and measures for data security. These include:
- High security over the servers and storage devices where the personal data is stored
- Secure transactions using SFTP and HTTPS technologies
- Access restrictions to personal data
- Staff training
- Regular monitoring and penetration testing
How long do we retain your data?
Whenever we collect your data, we only keep it for as long as it is necessary for the purpose for which it was collected. At the end of this period, we will either delete or anonymize your data.
Where do we store and process your personal data?
Our servers and all your data related to access to our demo portal and demo courses are located in the UK, and our staff who processed the data are located in the UK and the EU.
Your data is also stored on two cloud-based services provided by Hubspot and Microsoft. Both providers guarantee safeguards to protect your data and have adopted standard contractual clauses provided by the European Commission to comply with the GDPR. These providers act as passive data storage and apps providers to us - they are not authorised to access or process the data.
What rights you have in relation to your personal data that we hold?
You have the right to:
- Access your personal data free of charge
- Correct your personal data if it is incorrect, incomplete or out of date
- Stop us from using your personal data for direct marketing
- Stop us from processing your personal data
- Stop us from using your data for profiling automatic decision-making
To request a copy of your personal data, or to amend your personal data, please email us on firstname.lastname@example.org or write to us at:
Inmarkets Ltd, Salisbury House, Finsbury Circus, London EC2M 5QQ, UK
Inmarkets International Ltd, 1 Sqaq il-Ghadam, Mriehel BKR3000, Malta
If you've given us your consent to use your personal data, you have the right to change your mind and withdraw consent at any time.
Where we process your personal data on the basis of our legitimate business interest, you can ask us to stop processing, which we will do so unless we believe that we have an overriding reason to continue processing your personal data.
How can you stop your personal data from being used for direct marketing?
If you wish to stop receiving direct marketing communications from us just send us an email with the word "Unsubscribe" in the subject line and address it to email@example.com. You may also write to us:
- Inmarkets Ltd, Salisbury House, Finsbury Circus, London EC2M 5QQ, UK
- Inmarkets International Ltd, 1 Sqaq il-Ghadam, Mriehel BKR3000, Malta
Please note that you may continue to receive communications for her a short period after you've asked us to stop, while we update our records.
How can you contact the data protection regulators?
In the UK, if you feel that we haven't handled your data correctly, or you’re not happy with our response to any requests you have made in relation to your personal data, you have the right to complain to the Information Commissioners Office. You can contact them by calling +44 (0)303 123 1113.
Outside the UK, you have the right to lodge a complaint with the relevant data protection regulator in your country of residence.
How can you contact us?
If you have any questions relating to your personal data that have not been covered in this privacy notice, please contact our data protection liaison by emailing us on firstname.lastname@example.org.
We may update this privacy notice from time to time. If there are any significant changes we will notify you, but you are welcome to visit this page and review this notice at any time.
This privacy notice was last updated on 24/05/2018