Privacy and Cookies Policy

1.    Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.4    In this policy, "we", "us" and "our" refer to I-Next Limited.

2.    How we use your personal data

2.1    In this Section 2 we have set out:

(a)    the general categories of personal data that we may process;

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

2.2    We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3    We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us (or a company we have a data processing agreement with) and/or taking steps, at your request, to enter into such a contract.

2.4    We may process your information included in your personal profile on our website ("profile data"). The profile data may include [your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is the performance of a contract between you and us (or a company we have a data processing agreement with) and/or taking steps, at you request, to enter into such a contract.

2.5    We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include websites you can administer, external services you wish to access and appropriate credentials. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us (or a company we have a data processing agreement with) and/or taking steps, at your request, to enter into such a contract.

2.6    We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is the performance of a contract between you and us (or a company we have a data processing agreement with) and/or taking steps, at your request, to enter into such a contract.

2.7    We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.8    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us (or a company we have a data processing agreement with) and/or taking steps, at your request, to enter into such a contract.

2.9    We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.10    We may process information contained in any list subscription you submit to us regarding goods and/or services ("list subscription data"). The list subscription data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.11    In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.12    Please do not supply any other person's personal data to us, unless we prompt you to do so.

3.    Providing your personal data to others

3.1    We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3    We may disclose your personal data to subcontractors insofar as reasonably necessary for operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

3.4    In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.    International transfers of your personal data

4.1    In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2    We have a development and support subcontractor situated in the Ukraine. No personal data is transferred to or processed in the Ukraine. Individual engineers within the subcontractor may have access to personal data from databases hosted within the EEA and may be able to initiate processing of that data upon servers situated within the EEA. All such access will be protected by appropriate safeguards, namely the use of standard data protection clauses, a copy of which can be obtained from I-Next.

5.    Retaining and deleting personal data

5.1    This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3    We will retain your personal data as follows:

(a)    Service and usage data will be retained for a minimum period of 3 months, and for a maximum period of 12 months .

(b)    Account, profile and publication data will be retained as defined in the Platform Hosting Agreement.

5.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)    the period of retention of enquiry and correspondence data will be determined based on our email retention policy.

(b)    the period of retention of notification and list subscription data will vary according your requests and settings. Any ‘opt-out’ information is stored indefinitely against the associated email address. No other personal information is retained upon ‘opt-out’ .

5.5    Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6.    Security of personal data

6.1    We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

6.2    We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

6.3    Data relating to your enquiries and support transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

6.4    You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

6.5    You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

7.    Amendments

7.1    We may update this policy from time to time by publishing a new version on our website.

7.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

8.    Your rights

8.1    You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to: 

(a)    the payment of a fee (currently fixed at GBP 10); and

(b)    the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

8.2    We may withhold personal information that you request to the extent permitted by law.

8.3    You may instruct us at any time not to process your personal information for marketing purposes.

8.4    In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

9.    Third party websites

9.1    Our website includes hyperlinks to, and details of, third party websites.

9.2    We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10.    Personal data of children

10.1    Our website and services are targeted at persons over the age of 18.

10.2    If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11.    Updating information

11.1    Please let us know if the personal information that we hold about you needs to be corrected or updated.

12.    Acting as a data processor

12.1    In respect of data collected on client websites, we do not act as a data controller; instead, we act as a data processor.

12.2    Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

13.    About cookies

13.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

13.2    Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

13.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

14.    Cookies that we use

14.1    We use cookies for the following purposes:

(a)    authentication - we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: Apache);

(b)    status - we use cookies to help us to determine if you are logged into our website, to store information about your preferences and to personalise our website for you (cookies used for this purpose begin: SSESS);

(c)    analysis - we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: Apache); and

(d)    cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: cookie-agreed).

15.    Cookies used by our service providers

15.1    Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

15.2    We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: _gid, _ga, _gat.

15.3    We use the Google reCAPTHCA service on our enquiry form to prevent automated submissions. Links to the privacy and terms of use for this are shown wherever it is used .

15.4    We use Pingdom to understand how the website is performing. In certain configurations his service may use cookies for specific, anonymised performance information. You can view the privacy policy of this service provider at https://www.pingdom.com/legal/cookie-policy.

16.    Managing cookies

16.1    Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

16.2    Blocking all cookies will have a negative impact upon the usability of many websites.

16.3    If you block cookies, you will not be able to use all the features on our website.

17.    Our details

17.1    This website is owned and operated by I-Next Limited.

17.2    We are registered in England and Wales under registration number 03065542, and our registered office and principal place of business is at 11, Groves Lea, Mortimer, Reading, Berkshire, RG7 3SS.

17.3    You can contact us:

(a)    by post, using the postal address given above;

(b)    using our website contact form;

(c)    by telephone on 0118 931 3719;

(d)    as stated in your Platform Hosting Agreement if you have one

18.    Data protection registration

18.1    We are registered as a data controller with the UK Information Commissioner's Office.

18.2    Our data protection registration number is Z5081562.