Importantly, when you use iovox’s services ("Services"), we are a data processor as defined in the General Data Protection Regulation ("GDPR"). A data processor simply handles information provided to it, and as instructed, by a data controller; in this case that would be you as our customer.
We respect your privacy and do not sell, rent or loan any personally identifiable information ("Personal Data") collected on the iovox website ("Site") or when you use the Services. Any Personal Data that you provide to us via the Site or we collect when you are using the Services will be treated in a careful and secure manner.
- How to contact us.
- What Personal Data we collect.
- How we use your Personal Data and why.
- Who we share your Personal Data with.
- How we keep your Personal Data secure.
- Your Rights relating to your Personal Data.
- Marketing communications preferences.
- How long we store your Personal Data.
Please read the following policy carefully to understand our practices regarding your Personal Data and how we will treat it. Personal Data is the data that relates to you or identifies and/or can be used to identify you (this includes information relating to your name, email address, or other identifiers relating to you such as IP address). Personal data does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed). However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person). This policy explains how we collect, use and store the Personal Data you provide to us when you use our Services or Site.
We will only use personal information in the manner permitted by the relevant legislation and in accordance with the content of this policy, as amended from time to time. If you want to contact us about anything in this policy, please see the Contact section at the end of this document.HOW TO CONTACT US
You can contact us by emailing firstname.lastname@example.org.WHAT PERSONAL DATA WE COLLECT
All the Personal Data we collect as a data controller is outlined in the table below.
|Category of Personal Data collected||Information which may be included in this category|
|Identity Data||First name, last name, username or similar identifier, title.|
|Contact Data||Your billing address, email address and telephone numbers.|
|Financial Data||Any bank or credit card information needed to process invoices for our Services.|
|Transaction Data||A record of invoices that we’ve sent to you and when they were paid.|
|Marketing and Communications Data||Your preferences in receiving marketing from us.|
|Behavioural Data||Inferred or assumed information relating to your behaviour and interests, based on your online activity. This is most often collated and grouped into "segments" (e.g., there may be a segment for men, living in London and aged under 25, who like sports).|
|Technical Data||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 this website or use our services.|
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 do not collect any of your Personal Data form third party sources.HOW WE USE YOUR PERSONAL DATA AND WHY
We will only use your Personal Data for the purposes for which we collected it as listed below, 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 at email@example.com.
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.
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a "legal basis" for that use. We will only use your Personal Data when the GDPR allows us to – most commonly, we will use your Personal Data in the following circumstances:
- Where we need to perform a contract, we are about to enter or have entered into with you ("Contractual Necessity").
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests ("Legitimate Interests"). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below. However, broadly speaking, Legitimate Interests means our interests in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests.
- Where we need to comply with a legal or regulatory obligation ("Compliance with Law").
Generally, we do not rely on your consent as a legal basis for using your Personal Data. However, we may need and ask for your consent in relation to sending you third party direct marketing communications to you via email.
We have set out below the relevant purposes and legal bases for which we use your Personal Data – in addition, where relevant, we have also identified what our legitimate interests in that use might be.
Note that we may process your Personal Data for more than one legal basis depending on the specific purpose. Please contact us at firstname.lastname@example.org if you need details about the specific legal basis we are relying on to process your Personal Data in a specific circumstance where more than one basis is set out in the table below.
|Purpose||Category(ies) of Personal Data involved||Why do we do this||Our legal basis for this use of data|
|Account Creation||Identity Data Contact Data||To register you as a new customer.||Contractual Necessity|
|To process payments for the Services||Identity Data Contact Data Finance Data Transaction Data||To manage payments for the Services.||Contractual Necessity|
|Fraud Prevention||Identity Data Contact Data||To keep the Site and Services and associated systems operational and secure.||Legitimate Interests - we have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks.|
|Troubleshooting, testing and research||Technical Data||To track issues that might be occurring on our systems and to keep the Site safe and secure.||Legitimate Interests - it is in our legitimate interests that we can monitor and ensure the proper operation of our Sites and Services.|
|Marketing||Identity Data Contact Data Marketing and 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 will receive marketing communications from us if you have requested information from us or purchased a subscription to the Services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.||Legitimate Interests - we have a legitimate interest in providing you with updates on our Site and Services where you have purchased similar services from us.|
The table below describes who we share your Personal Data with, what we share and why we share it.
We share your Personal Data within the iovox Group. This will involve transferring your data outside the European Economic Area ("Europe"). Some of our service providers may also be based outside Europe. We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
- If we elect to use service providers outside Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
- Where we use service providers based in the U.S., 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 Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.
|Recipients||Category(ies) of Personal Data we share||Why we share it||Location(s)|
|Professional advisers||Identity Data Contact Data||Our lawyers, bankers, auditors and other professionals provide consultancy, banking, legal, insurance and accounting services among other things.||Within Europe|
|Service Providers||Identity Data Contact Data Technical Data||Our service providers provide us with IT and system administration services.||Within Europe|
|Regulators and other authorities||Identity Data Contact Data||Authorities may require reporting of processing activities in certain circumstances.||Within Europe|
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. Using cookies helps us to provide you with a good experience when you browse our website and allows us to improve our site.What cookies do we use?
We use Session Cookies, which are only recorded whilst your browser session is active. Once the session is closed, the cookie is automatically deleted and cannot be used for long term tracking. We use Session Cookies for several reasons including:
- 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 if we make those available in the future.
- Analytical/performance cookies. This includes Google Analytics which uses its own cookies. You can find out more information about Google Analytics cookies here. You can also find out more about how Google protects your data here. These analytics 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.
- 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 advertising displayed on it more relevant to your interests.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, as mentioned above, if you use your browser settings to block all cookies (including essential cookies) it may mean that not all the functions on the site can work properly. You can disable cookies which remember your browsing habits and target advertising at you by visiting this site. If you choose to remove targeted or advertising cookies, you will still see advertisements, but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioural advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.HOW WE KEEP YOUR PERSONAL DATA SECURE
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.YOUR RIGHTS RELATING TO YOUR PERSONAL DATA
By law you have the right to:
- Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- 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 exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. 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. This right only exists where we are relying on consent to process your Personal Data ("Consent Withdrawal"). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
If you want to exercise any of the rights described above, please contact us at email@example.com.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, 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 several requests. In this case, we will notify you and keep you updated.
If you feel that your complaint has not been adequately resolved, please note that you have the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.MARKETING COMMUNICATIONS PREFERENCES
No Spam, not now, not ever! You will receive emails from us for information update purposes. However, we will never supply, sell or rent your email address or any other information to any third party, other than if we sold some or all the company to another party.
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. Where you opt out of receiving marketing messages, this will not apply to Personal Data provided to us because of your use of our Services where we may need to inform you of changes to the Service offered or interact with you regarding technical or customer support related services among other things.HOW LONG WE KEEP YOUR DATA
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above, unless a longer retention period is required by law (for example for regulatory purposes).
The table below shows our standard retention practices:
|Category of Personal Data||Retention period|
|Identity Data||For so long as retention is necessary to fulfil the purposes/use for which it is used. For example, continued interactions with you as a customer of ours.|
|Contact Data||For so long as retention is necessary to fulfil the purposes/use for which it is used. For example, continued interactions with you as a customer of ours.|
|Financial Data||For so long as retention is necessary to fulfil the purposes/use for which it is used. For example, continued interactions with you as a customer of ours.|
|Marketing and Communications Data||For so long as you remain a customer of ours or continue to opt-in to receive communications from us.|
This Site is not intended for children below 16 and we do not knowingly collect data relating to such children.CONTACT
If you have any questions or comments regarding this policy, or your dealings with our team, please contact us at firstname.lastname@example.org.