Full Privacy Policy - Privacy Policy Data controllers, Clients and Website visitor
For those who use our products and services, or visit our website (other than as a survey participant)
This policy applies to all personal information for which we are the data controller. As you are the Data Controller for your Participant Data and Questionnaire Data , different principles often apply to it and where relevant we include a note on Participant Data at the end of each section.
- The information we collect about you
- How we use your information
- Who we share your information with
- Links to other websites
- Your rights as a data subject
- How long we keep your information
- Security of your information
- International transfers of information
- Changes to our privacy policy
- The information we collect about you
We collect information about you when you provide it to us, when you use our products, services and website and / or are introduced to us by an authorised third party, as follows:
Account information: where you use our products or services, or create an account with us, we collect information from you such as your name and email address, username, phone number, address and organisation. We also ask for and collect personal information such as an email address and name from any individual that you authorise to use our products or services through your account.
Billing information: where you need to make a payment to us for our products or services, we collect your billing details, including a billing address and financial and payment information.
Information that you provide to us: we collect the information that you give to us, for example when you:
- contact us by phone, email, online chat or otherwise.
- fill in forms on our website.
- sign up for our newsletters and promotions.
- respond to a survey run by ourselves (e.g. to get feedback on our own services and training courses).
- contact us for customer support.
Technical information: applicable to Branded Partners with Insightful Edge. We may collect information relating to your interaction with our products, services and website, including the type of browser and/or device used, operating system, files viewed, date/time stamp, referrer page and IP address.
Cookies: we use cookies to distinguish you from other users of our products, services and website. This helps us to improve our website’s performance and your experience of using our website. You can control the use of cookies at the individual browser level. Some of those cookies are necessary for the use of our services. If you reject cookies, you can still use our website, but your ability to use some features or areas of our website may be limited.
Web beacons: when we send you emails, we may include a web beacon to allow us to determine the number of people who open our emails and information such as when and how many times the email was viewed, whether any links were clicked on, whether the email was forwarded, your geographic location and browser and device type. This helps us to measure the effectiveness of our email campaigns. When you click on a link in an email, we may record this individual response to customise our offerings to you. Web beacons can be refused when delivered via email. If you do not wish to receive web beacons via email, you will need to disable HTML images or refuse HTML emails via your email software, but please note that this is likely to reduce the functionality of such emails.
Social media features and widgets: our website includes social media features, These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing them.
Information from other users: other users of our products or services may provide us with information about you. For example, when another individual authorises you to use our products and services, they will provide us with your name and email address, or an individual in your organisation may provide us with your contact information if they designate you as the necessary contact for delivery of part of the contract. For example: a billing, regional, or technical contact on the Client organisation’s account.
Participant Data: if you are a Clients using our survey products and services you may provide contact information of potential survey participants (Participant Data) and we collect your survey response data for you. We process it solely in accordance with the agreement between us.
The way in which we process many of our questionnaires and surveys supports the anonymity of participants as such we will be legitimately unable to give you access to raw Questionnaire Data. It is possible to release raw data on request only where there was agreement with us and, notification and transparency with participants before commencing the survey; for example: a bespoke customer survey.
- How we use your information
We use the information that we hold about you in the following ways. For each of these, we have identified our legal basis for processing your information in that way.
This section does not relate to your Participant Data – we process this in accordance with your instructions and our agreement with you.
Providing our products and services: we use your information to provide you with the products and services which you have subscribed to or requested. This may include providing you with Clients support and with the benefits of any feature associated with the relevant product or service. This processing is necessary to perform our contract with you for these products and services.
Responding to enquiries: we will use your contact information and any information that you send to us to respond to your questions, requests for information or complaints. Depending on the nature of your enquiry, we may do this on the basis of performing our contract with you, our legal obligations, or our legitimate interests of providing you with the best service and understanding how we can improve our products and services based on your experience.
To protect our business, products, services and website: we will use your information in accordance with our legitimate interests of administering and maintaining our systems and ensuring network and information security, for example to prevent unauthorised access to our networks, to investigate faults, to control the abuse of our products or services, to prevent denial of service attacks and to monitor system usage and server load.
To develop, test and improve our products, services and website: we will use your information about how you use our products, services and website to improve the user experience for our users, for example to ensure we are offering appropriate features, supporting appropriate browsers and devices and to ensure our website content is presented in the most effective manner.
Monitoring and enforcing our rights: we may use your information to ensure that you are using our products and services in accordance with the terms on which they are supplied, and to enforce those terms, our website terms of use, or other relevant agreements that we have with you, in accordance with our legitimate interests of being able to enforce our rights.
Legal requests: we may need to use your information to comply with a legal obligation such as to respond to a court order or a request from a supervisory authority or government, or to prevent fraud.
Notifications: we will use your information to send you communications which are required by law or to notify you of changes to our terms or this privacy policy, or changes (permanent or temporary) to our products or services. Such messages will not include any promotional content. Depending on the nature of the communication we may do this on the basis of performing our contract with you or complying with our legal obligations.
Surveys and feedback requests: we may use your information to invite you to participate in surveys run by us on our own behalf, for example to invite your feedback on our products, services and website. These communications will not contain any promotional content and will be sent on the basis of our legitimate interests of improving our products, services and website. However, if you would prefer not to receive such communications, please contact us at dpa@insightfuledge.com.
Marketing: we may use your information to provide you with information about our products and services, offers and events that we consider may be of interest to you. This information will relate to our own products and services only, and we will not provide your information to third parties for marketing purposes. We send these communications either on the basis of your consent (where you have specifically consented to receiving such communications) or in accordance with our legitimate interests of growing our business.
You may stop receiving marketing communications from us at any time. To withdraw your consent or to opt-out of receiving marketing communications, you may contact us at dpa@insightfuledge.com or by using the unsubscribe options in our maketing email.
Legal basis for processing:Under GDPR we are required to have legal basis for processing data of any individual natural person. As an organisation registered in England, we apply the same standard of service and processing for all our clients around the globe. This will be one of the following:
- where we require the information to perform a contract with you (e.g. to deliver the services that you have requested);
- where we have your consent to do so, and in this case you have the right to withdraw or refuse to give your consent at any time. This will not however affect the lawfulness of any processing based on your consent before you withdraw it;
- where the processing is necessary for our legitimate interests (and those legitimate interests are not overridden by your interests or fundamental rights and freedoms); or
- where we need to comply with a legal or regulatory obligation.
If you have any questions about or require further information concerning the legal basis on which we collect and use your information, including regarding our legitimate interests, please contact us.
- Who we share your information with
We will only disclose your information in the circumstances below:
Our service providers: we may disclose your information to our third party service providers. In each case we have agreements in place with the service provider to ensure that they provide appropriate protection for your information and to ensure that they are only permitted to use your information in accordance with our instructions and as necessary to provide the relevant service to us.
For example, we engage third parties to provide the following services:
- hosting our online survey services and our website.
- Sending and managing our Clients and participants communications.
- providing our online chat services.
- provide analytics information.
- Development of products and features.
- Sub-processors who may access data to support analysis
Professional advisers: we may need to disclose your information to our professional advisers, including our lawyers, bankers, auditors and insurers.
Compliance with legal obligations and enforcement of our rights: we may also have to disclose your information if this is reasonably required to:
- comply with any applicable law, regulation or legal process or to respond to a request from a government or a regulatory body.
- enforce our agreements, policies and website terms of use.
- protect the security or integrity of our products and services.
Other users within your organisation: where your organisation purchases products or services from us covering multiple authorised users and contacts, we may disclose your information to other users within your organisation, in order to deliver or products and services.
- Links to other websites
This privacy policy covers our products, services and website. Our website may contain links to and from third party websites. The information practices and the content of such other websites are governed by the privacy policy of that website. Please note that we cannot accept responsibility or liability for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy practices as us. We encourage you to review the privacy policies of any third party before you submit any personal data to them.
- Your rights as a data subject
At your request we will provide you with information about whether we hold any of your personal information and provide a copy of this information to you. To request this information please contact us at dpa@insightfuledge.com. You may update, amend or request deletion of your personal information as described.
Where Insightful edge is the Data Controller of the information you have the right to exercise additional rights available to you, including:
Right of Erasure (Right to be forgotten): in certain circumstances you have the right to erasure of personal information held about you, although this may be qualified where e.g. it is necessary for that information to be retained for record keeping purposes or compliance with our obligations. If we are unable to comply with your request, we will explain why.
Right of Rectification: you have the right to have your personal information rectified if it is inaccurate or incomplete.
Right to withdraw consent: you have the right to request that we stop processing your personal information for marketing purposes, and can request that we stop processing your personal information for other purposes based on our legitimate interests. In some cases, we may be able to demonstrate that we have compelling legitimate grounds to continue to process your information.
Right of Restriction: you may have the right to request that we restrict the processing of your personal information (e.g. where you believe that the personal information we hold about you is inaccurate or unlawfully held).
Right to Data Portability: Is more challenging as in some cases you are using proprietary products using our IP so whilst data may be available, certain system information may be removed. You may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information provided by you to another data controller.
You also have the right to withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you would like to exercise such rights, please contact us at dpa@insightfuledge. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. In the UK, this is the Information Commissioner’s Office https://ico.org.uk/.
- How long we keep your information
We will retain your information for as long as your account is active or as needed to provide our products or services or otherwise fulfil the purposes described in this policy, including for the purposes of satisfying any legal, accounting or reporting requirements. If you wish to delete your personal information at any time, please contact us at dpa@insightfuledge. If we are unable to comply with that request, for example because we need to retain some or all of your information to comply with a legal obligation, we will let you know and will explain why.
Questionnaire Data: you are in control of the management of your Questionnaire Data and can request for it be deleted from our online systems at any time. As standard we will hold on to Questionnaire Data for 5 years and following that it remains for up to a further 12 weeks in our back ups before being permanently deleted.
- Security of your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your PII stored on our Sites or controlled by us.
Sensitive and private data exchange between you and our Sites happens over a SSL secured communication channel and is encrypted and protected with digital signatures.
While we use appropriate technical and operational measures to keep your PII secure, the transmission of information via the internet is not within our control and is not completely secure. Although we will do our best to protect your PII, we cannot guarantee the security of your PII sent to us by email. Any such transmission is at your own risk. Once we have received your PII, we will use strict procedures and security features to try to prevent unauthorised access.
Our data centre providers are ISO27001 certified, and your Questionnaire Data is encrypted on the servers at rest and in transit across the internet.
- International transfers of information
Insightful Edge partner with clients around the globe.
As a result, we may transfer your personal information to countries outside the EEA (the EU member states plus Norway, Liechtenstein and Iceland) for the purposes set out in this privacy notice.
Where this is applicable, we take steps to make sure that when we transfer your personal information appropriate protection is in place. Often, this protection is set out under a contract with the Client or Individual who receives that information.
- Changes to our privacy policy
We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will post a notice on the homepage of our website, and/or we will send an email notification to our Partners and Clients.