WHO WE ARE
WHAT DATA ABOUT ME IS COLLECTED AND HOW IS IT USED?
Which Personal Data We Collect
Personal Data is information that identifies you or can be used to identify or contact you (“Personal Data”). Such Personal Data may include your name, address, email address, telephone number, birth date (primarily for eligibility purposes) and billing and credit card information.
How We Collect And Use Your Personal Data
If You Use Our Internet Products
We collect information, some of which contains Personal Data, that you provide directly to us when you choose to use our Internet Products, available either for free or on a subscription basis. We also collect data that you provide directly to us through responses to special Internet Products such as surveys, questionnaires, self-assessment quizzes, contests and the like. We use this data to personalize our Internet Products and to optimize your customer experience when using our Website.
Moreover, we automatically collect information including Personal Data when you browse our Website or use our Internet Products, such as your IP address, browser type, operating system, error logs, and other similar information. Such aggregated information does not allow us to identify you and is used by us to analyse trends, to administer the Website, to monitor our Website’s use, and to gather general information about the use of our Website.
The legal basis for such processing of your Personal Data are our legitimate interests (Art. 6(1)(f) GDPR) in customizing the content of our services in line with user preferences and in further improving our Internet Products.
Please note that you are not legally required to provide us with your Personal Data. However, without your Personal Data we will not be able to provide you with our Internet Products.
If You Become A Community User Or Subscriber
In order to access certain Internet Products on our Website or if you create an account to become a client, you must first complete certain steps. During these steps, you will be required to provide us with Personal Data such as your name, postcode and email address, and, if you subscribe to one of our Internet Products, credit card and billing information. This data is used to provide you with the requested Internet Products or for subscription billing purposes.
Such processing of your Personal Data is necessary for the performance of our services. The legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. You are contractually required to provide us with such information and without such information we are not able perform the services as described above.
If You Purchase a Product On Our Website
If you place an order, you will need to have an account and the first time you will be asked to provide your name, postal address, billing address, payment details, email address and your telephone number.
We will use your name and email address to send you an order confirmation email and the access to the product you have purchased. We will also use your payment details to process payment for your order. Such processing of your Personal Data is necessary to process your order; the legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data we will not be able to send you order-related communications or to fulfil your order.
If We Send You Service Updates
We use your Personal Data to send you important service announcements and updates regarding our Website or Internet Products or, if you are a subscriber, about your billing account status. When you subscribe to our Internet Products, we will send you a welcome email to provide transactional information about your subscription or to verify your username and password. Such service announcements and updates contain important information relevant to your use of our Website and/or our Internet Products.
The processing of your Personal Data for such purposes is necessary for the performance of our services. The legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data we will not be able to send you service-related communication.
If You Contact Our Customer Service
If you contact our customer service, we will communicate with you in response to your inquiries, to provide the services you request, and to manage your subscription. We will communicate with you by email or telephone, in accordance with your preferences.
Such processing of your Personal Data is necessary for the performance of our services; the legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data we will not be able to send you customer service related communications.
If You Subscribe To Newsletters And Other Marketing Communications
When subscribing to our Internet Products or elsewhere on our Website you have the option to consent to receiving newsletters and other information on our products and services. If you “opt-in” we will send you promotional newsletters and inform you about offers, events and surveys via e-mail and through social media platforms. The legal basis for such processing of your data is your consent (Art. 6(1)(a) GDPR) or – if you are an existing customer or subscriber – our legitimate interest (Art. 6(1)(f) GDPR) in providing you with relevant marketing information. Please note that you are not legally required to provide us with your Personal Data. However, without your Personal Data we will not be able to send you our newsletters and other information as described above. You have the option to opt-out of these types of communication at any time by following the respective instructions in such communication.
A cookie is a small data file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. The length of time a cookie will stay on your computer or mobile device depends on whether it is a "persistent" or "session" cookie. Our Website uses both types of cookies. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted.
We use the following types of cookies on our website:
- Strictly necessary cookies: These cookies are essential for you to use our Website and our Internet Products.
- Performance cookies: These cookies collect information about how you use our Website. We use such data to help optimize our Website and make it easier for you to navigate and use our Internet Products.
- Functional cookies: These cookies allow our Website and Internet Products to remember the choices you make using our Website and personalize your experience.
- Analytics cookies: We may use analytics cookies to help us understand how users browse our Website and how they arrived at our Website. We use a variety of website analytics providers such as Google Analytics, Hot Jar, Optimizely and Exact Target. These cookies are subject to the respective privacy policies of the external service providers and to learn more about your options and how to opt-out of such analytics cookies visit the respective providers web site for details.
SOCIAL PLUG-INS AND OTHER THIRD-PARTY FEATURES
HOW WE SHARE AND DISCLOSE PERSONAL DATA
We will not share, sell, transfer or otherwise disseminate your Personal Data to third parties, unless required by law according to Art. 6(1)(c) GDPR, unless required for the purpose of your contract according to Art. 6(1)(b) GDPR, unless the third party acts as a data processor on our behalf according to Art. 28 GDPR or you have given us express consent to do so according to Art. 6(1)(a) GDPR.
We may share some of your Personal Data with another IMPULS company located in Europe to provide hosting services to us.
We may also use third-party service providers to offer or facilitate services on our behalf and share your Personal Data with such providers to the extent necessary for such providers to perform their services on our behalf. In particular, we may use a mailing company to dispatch email marketing messages, payment service providers to bill you for goods and services and for credit card processing, specialist providers for payment collection and fraud screening, a shipping company to fulfil orders, a call center provider to facilitate customer service, social media and other agencies to manage our social media and other advertising campaigns, a cloud provider for our CRM system and an external provider for the hosting of our Website.
Some of the companies we share your Personal Data with as described above are located outside of the European Economic Area.
In order to grant sufficient protection of your Personal Data in this context, we use standard data protection clauses adopted by the European Commission according to Art. 46(2)(c) GDPR with such companies or certifications of such companies under the EU-U.S. Privacy Shield according to Art. 45(1) GDPR. You can request further details by contacting us at the contact details as mentioned below.
We may also be required to disclose your Personal Data to government or law enforcement officials in response to a lawful request by a public authority or if we have to do so to comply with a legal obligation, including to meet national security or law enforcement requirements according to Art. 6(1)(c) GDPR. We can also disclose your information in order to pursue our legitimate interest in applying or enforcing our terms and conditions or in responding to any claims, in protecting our rights or the rights of a third party, in protecting the safety of any person or in preventing any illegal activity (including for the purposes of fraud protection and credit risk reduction) according to Art. 6(1)(f) GDPR.
If required under applicable data protection laws, we will collect your prior consent before sharing your Personal Data with other companies. In such cases, the legal basis is Art. 6(1)(a) GDPR.
IS MY PERSONAL DATA USED FOR ANY OTHER PURPOSES?
WHAT RIGHTS DO I HAVE?
You have the following rights:
Right of access (Art. 15 GDPR):
You have the right to request confirmation as to whether we process your Personal Data and where that is the case, to request access to the Personal Data we hold about you.
Right to rectification (Art. 16 GDPR):
You have the right to request the correction of inaccurate Personal Data.
Right to erasure (Art. 17 GDPR):
You have the right to request erasure of Personal Data without undue delay under certain circumstances, e.g. if your Personal Data is no longer necessary for the purposes for which it was collected or if you withdraw consent on which our processing is based according to Art. 6(1)(a) GDPR and where there is no other legal ground for processing.
Right to restriction of processing (Art. 18 GDPR):
You have the right to request us to restrict the processing of your Personal Data under certain circumstances, e.g. if you think that the Personal Data we process about you is incorrect or unlawful.
Right to data portability (Art. 20 GDPR):
Under certain circumstances, you have the right to receive your Personal Data you have provided us with, in a structured, commonly used and machine-readable format and you have the right to transmit that information to another controller without hindrance or ask us to do so.
Right to object (Art. 21 GDPR):
You have the right to object to the processing of your Personal Data under certain circumstances, in particular if we process your Personal Data on the legal basis of legitimate interests (Art. 6(1)(f) GDPR) or if we use your Personal Data for marketing purposes.
You can assert your above mentioned rights by contacting us at the contact details mentioned below.
RIGHT TO LODGE A COMPLAINT BEFORE THE DATA PROTECTION AUTHORITY
You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that our processing of your Personal Data infringes the applicable data protection laws. Please contact us at the contact details mentioned below and we will assist you to identify the respective competent supervisory authority.
We store your Personal Data and other information for as long as necessary to enable you to use our Website and our Internet Products, to provide our services to you, to comply with applicable laws (including those regarding document retention), to resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. If you have a question about a specific retention period for certain types of Personal Data we process about you, please contact us at the contact details mentioned below.
CONFIDENTIALITY OF THE USER PASSWORD
The User is responsible for the confidentiality of the password that allows him to access his account on our Website.
He undertakes to keep this password secret and not to communicate it to anyone.
AUTOMATED INDIVIDUAL DECISION-MAKING
We do not use your Personal Data to make decisions with legal or similar effects for you based on the automated processing of your Personal Data only.
WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?
71-75 Shelton Street
WC2H 9JQ Greater London
All right reserved - IMPULS LTD © 2019