Privacy Policy

Introduction

This is the privacy notice for the Iris Worldwide group of companies.

Iris Worldwide respects your privacy and is committed to protecting your personal data.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice will inform you as to how we look after your personal data when you visit our websites (regardless of where you visit it from), use our services, or register to attend our events. We are committed to protecting your personal data and this privacy notice will explain how we look after it, what rights you have, as well as how the law protects you.

The Iris Worldwide group is made up of different legal entities and this privacy notice is issued on behalf of the Iris Worldwide group so when we mention “Iris”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Iris Worldwide group responsible for processing your data. Iris Nation Worldwide Limited is the controller and responsible for this privacy notice.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Iris Nation Worldwide Limited

Data Protection Officer’s email address: dpo@iris-worldwide.com

Postal address: 3rd Floor, 10 Queen Street Place, EC4R 1BE

Changes to the privacy notice and your duty to inform us of changes

This version was last updated in June 2021.

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.

How this privacy notice operates with our other privacy notices

It is important that you read this privacy notice together with any other supplemental notices that we may provide on specific occasions when we are collecting or otherwise processing personal data about you so that you know how and why we are using it. This privacy notice supplements those supplemental notices and is not intended to override them.

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:

We also collect, use and share for any purpose “Aggregated Data” such as statistical or demographic data. 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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

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

4. How we use 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:

Purposes for which we will use your personal data

We may use your personal data to:

Marketing information from us

We may use your Identity, Contact, Technical, Usage and Profile 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 (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing. This is in line with our legitimate interest.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Iris Worldwide group of companies for marketing purposes.

Opting out

We try to always include an opt out option of any marketing messages. Where this is not possible, you can ask us to stop sending you marketing messages at any time by contacting us

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

Cookies

For more information about the cookies we use, please see our cookies policy

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 may have to share your personal data with other organisations from time to time, but we will maintain responsibility for what they do with your data and how it is processed. 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 providers to use your personal data for their own purposes and we only permit them to access your personal data for specified purposes and in accordance with our instructions – for example, service providers who process data for us, including those providing IT and system administration services and hosting.

6. International transfers

Generally, we process your personal data within the EEA. If we need to transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it as if it were being processed within the EEA. By way of example:

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 also 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

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Should you wish to access your data, please note the following:

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

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