INNOCEAN Worldwide UK Ltd (INNOCEAN UK) is committed to protecting your privacy. We are providing this privacy notice to tell you about how we collect and process your personal data when you visit our website or engage with us as a client, prospective client, or supplier.
INNOCEAN UK is the data controller for the processing that we undertake that is outlined in this privacy notice. As the data controller, we are responsible for deciding how we hold and use the personal information we collect.
If you have any questions about how we process personal data or this privacy notice, would like to exercise your data protection rights, or submit a complaint about how we have handled your personal data, you can contact us using the details below:
2nd Floor, 6 Ramillies Street
Throughout this document we refer to Data Protection Legislation which means the Data Protection Act 2018 (DPA2018), United Kingdom General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with the aforementioned legislation. Where we process the personal data of people in the European Union, it also includes the EU General Data Protection Regulation (EU GDPR). This includes any replacement legislation coming into effect from time to time.
Categories of Data
We only collect personal information that we know we will genuinely use and in accordance with the Data Protection Legislation. The type of personal information that we will collect about you, from third party websites or that you have otherwise voluntarily provided to us includes:
- Your name;
- Telephone number(s);
- Email address;
- Your company;
- Job title;
- Cookies; and/or
- IP address.
We may, in further dealings with you, extend this personal information to include your purchases, services used, and subscriptions, records of conversations and agreements and payment transactions.
You are under no statutory or contractual requirement or obligation to provide us with your personal information; however, we require at least the information above in order for us to deal with you as a prospect or client in an efficient and effective manner.
Purposes of Processing and Legal Basis
Whenever we process your personal data, we always identify a lawful basis for processing.
The legal basis we mainly rely on for processing personal data is Article 6(1)(f) of the UK GDPR which relates to processing that pursues our legitimate interests, provided your interests and fundamental rights do not override those interests. The purposes for which we rely on this lawful basis are:
- To contact you, following your enquiry or to reply to any questions;
- To send B2B marketing communications to you;
- To deal with any customer service enquiries, reply to any suggestions, issues or complaints you have contacted us about;
- To deal with your organisation as a prospect, including drawing up a proposal and contract and communicating with you for this purpose;
- To fulfil the contract we have with your organisation to provide you with the agreed service;
- To process any payment made by your organisation for the services provided;
- To request your feedback in order to improve our service;
- To power our security measures and services so you can safely access our website;
- To deal with your organisation as our supplier, where applicable.
In a small number of circumstances, we will seek your consent (Article 6(1)(a) of the UK GDPR) to process your personal data:
- To use marketing and analytics cookies on our website.
For more information on the essential and non-essential cookies that we use on the website, please visit our consent management platform by clicking ‘Manage’ on our cookie banner.
How we Collect Your Personal Data
We may collect your information when you:
- Visit our website;
- Interact with our social media accounts; or
- Contact us by email, call or post.
We may also receive your information indirectly from third parties including from:
- Someone else in your organisation;
- From another of our clients if you have asked to be referred;
- Third party lead gen organisations who carry out prospecting on our behalf.
Sharing your information
INNOCEAN UK may transfer your personal data for the respective purposes to the recipients and categories of recipients listed below:
- Private third parties – Affiliated or unaffiliated private bodies other than us, such as Vimeo;
- Data processors – Certain third parties, whether affiliated or unaffiliated, may receive your personal data to process such data on behalf of INNOCEAN UK under appropriate instructions as necessary for the respective processing purposes. The data processors will be subject to contractual obligations to implement appropriate technical and organisational security measures to safeguard the personal data, and to process the personal data only as instructed;
- Governmental authorities, courts, external advisors, and similar third parties that are public bodies as required or permitted by applicable law; and
- On occasion we may use a third parties to source and contact prospective clients on our behalf. We rely on the corporate subscriber exception to do this, and always provide an opportunity for recipients to opt out of every communication.
We may share your personal data with third parties located outside of the UK. Where we share your personal data with third parties located in countries that are not covered by an adequacy decision, we rely on standard contractual clauses with the UK Addendum to safeguard the transfer.
Retaining your information
Your personal information will be retained in accordance with our retention policy which categorises all of the information held by INNOCEAN UK and specifies the appropriate retention period for each category of data. Those periods are based on the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and INNOCEAN UK’s business purposes.
For information related to you and your organisation’s contract with us as a client or supplier, we generally keep information for 7 years from the end of our relationship with you. If there is a dispute or a legal action, we may need to keep this personal information longer.
For website cookies, you can find the various retention periods applicable by clicking on ‘Manage’ in our consent management platform.
Protecting your information
Data security is of great importance to INNOCEAN UK and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure your collected data.
We take security measures to protect your information including:
- Limiting access to our buildings to those that we believe are entitled to be there by use of passes and monitoring our offices with CCTV;
- Implementing access controls to our information technology. Any access to your personal data at INNOCEAN UK is restricted to those individuals that have a need to know in order to fulfil their job responsibilities;
- Utilising technical measures such as firewalls, anti-virus software, and encryption to safeguard the data we hold; and
- Implementing organisational measures such as regular staff training and awareness exercises, internal information security policies, and data handling procedures to ensure our staff are aware of how to process personal data securely and responsibly.
You have the right to:
- ask for access to your personal information via a ‘subject access request’;
- ask for personal information we hold about you to be corrected;
- ask for your personal information to be deleted. This enables you to ask us to delete or remove your personal information where there is no good reason for us continuing to process it;
- object to the processing of your personal information where we are relying on a legitimate interest, and there is something about your particular situation which makes you want to object to processing it;
- ask for the processing of your personal information to be restricted. This enables you to ask us to suspend the processing of personal information about you; and
- ask for your personal information to be transferred to another company.
You can exercise any of the following rights by contacting us using the contact information outlined above.
Where we rely on consent to process your personal data, you have the right to withdraw your consent at any time. You can do this by navigating to our consent management platform on our website.
Any requests received by INNOCEAN UK will be considered under applicable data protection legislation. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner’s Office at www.ico.org.uk.
Our website may contain links to third party websites. This privacy notice doesn’t cover how organisations that own the external websites process your personal data. We encourage you to read the privacy notices on the other websites you visit.
For example, we deliberately decided against the use of social media plugins. This means that when you visit our website, there is no automatic transmission of your user data to the social network servers such as Facebook, Instagram, Twitter or similar. Instead of the social media plugins we have decided on mere hyperlinks, so that your personal data is not passed on in advance to the social media services.
If you wish, you can connect to social networks like Facebook, Twitter or Instagram via our website. However, this only happens if you consciously click on this link.
Addresses of the respective provider and URL with their privacy notices:
Changes to this privacy notice
We keep this policy under regular review. We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices.
Last updated July 2023.