Privacy Notice 

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1. Important information and who we are

 

Purpose of this privacy notice

This privacy notice aims to give you information on how Inulox Ltd (“Inulox”, “we”, “us”, “our”) collects and processes your personal data, including any data you may provide through this website.

 

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

 

Controller

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

 

Full name of legal entity: Inulox Ltd

Email address: contact@inulox.com

Postal address: Inulox Ltd, 30 Upper High Street, Thame, Oxfordshire, OX9 3EZ, UK

 

You have the right to make a complaint at any time to your respective supervisory authority. The Information Commissioner's Office (ICO) is the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

 

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.


 

2. The data we collect about you

 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, title and gender.

  • Contact Data includes email address and telephone numbers.

  • Technical Data includes 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. 

  • Usage Data includes information about how you use our website, products and services. 

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.


 

3. How is your personal data collected?

 

We use different methods to collect data from and about you including through:

 

Direct interactions. You may give us your Identity and Contact Data by emailing us. This includes personal data you provide when you:

  • request our services;

  • subscribe to our publications;

  • request marketing to be sent to you; or

  • give us some feedback.

 

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using Cookies. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. Essential Cookies are placed on our website by Wix.com to improve the functionality of our website. Cookies help us:

  • Ensure the platform is safe and secure;

  • Ensure a smooth experience for website visitors; and

  • Monitor and analyse the performance, operation and effectiveness of our website.

 

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:


 

4. Legal basis for using your personal data

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

 

Cookies

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

 

Our website is hosted on the Wix.com platform. Your Technical Data (including Cookies) and Usage Data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. Wix.com stores your data on secure servers behind a firewall.

 

Change of purpose

 

We will only use your personal data for the purposes for which we collected it, 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.

 

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.

 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


 

5. Disclosures of your personal data

 

We will not share your Personal Data with third parties unless we are required to by law or it is compatible with the purpose for which the data was collected. The third parties we may share your data with are set out in the Glossary.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for the specified purposes and in accordance with our instructions.


 

6. International transfers

 

Many of our external third parties are based outside the UK and the EEA so their processing of your personal data will involve a transfer of data outside the UK and the EEA.

 

Whenever we transfer your personal data to external third parties based outside of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government or the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

  • Where we use certain service providers, we may use specific contracts approved by the UK Government or the European Commission which give personal data the same protection it has in the UK and the EEA. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. 

 

Please contact us if you want further information on our protective measures relating to international transfers.


 

7. Data security

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


 

8. Data retention

 

The time periods for which we retain personal data are based on business needs and legal requirements.  We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected and any other permissible, related purposes. For example, we may retain certain information to comply with regulatory requirements regarding the retention of such data, or in the event a litigation hold is imposed.  When personal data is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.


 

9. Your legal rights

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

 

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

Request the transfer of your personal data to you or to a third party. 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 at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent

 

If you wish to exercise any of the rights set out above, please contact us.

 

What we may need from you

 

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.

 

Time limit to respond

 

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 a number of requests. In this case, we will notify you and keep you updated.


 

10. Glossary

 

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

Third parties

 

External third parties

  • Service providers: acting as processors who provide IT and system administration services;

  • Professional Advisors: Accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors in all of the countries in which the we operate;

  • Public and Governmental Authorities: Entities that regulate or have jurisdiction over us such as regulatory authorities, public bodies, and judicial bodies, including to meet national security or law enforcement requirements; 

  • Third Parties in Corporate Transactions: in connection with any proposed or actual reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the our business, assets or shares (including in connection with any bankruptcy or similar proceedings).