This Privacy Notice last changed on 24th May 2018
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We are International Management Group (UK) Ltd and respect your privacy.
Your personal information is collected by International Management Group (UK) Ltd: 00946580
International Management Group (UK) Ltd‘s contact details are as follows:
IMG UK Ltd
566 Chiswick High Rd
If you have questions, please contact the Privacy Counsel, EMEA at:
Data collection and usage
Sources of data
Automated decision making
Legal and other requirements
How long we keep your information
Information we share
Where your information will be held
Right to object
Analysis and advertising
Cookies and Similar Technology
Tracking in our Apps
Links to third party websites
Changes to the notice
How to contact us
We will collect store and use your personal information
- to conduct our business;
- to allow access to this website, register / subscribe / buy / use our products and services;
- to allow access to and use of our mobile applications [and games] (“Apps”);
- to meet our legal obligations;
- to fulfil any purpose we make known to you when we collect your personal information; and
- to fulfil other purposes set out in more detail in this section.
[Certain types of personal information are more sensitive than others. “Special information” about you includes information about health, disability, race, ethnicity, [political opinions],] biometrics] or [religion]. We may collect and receive special information about you.
We have identified here the types of information we may collect or receive, how we will use it and why we will use it.
The table below explains what information we collect and how and why we use it.
[Please note: that when information is shared with a third party, it is also necessary to explain the legitimate interests relied on by the third party, when that is the relevant legal basis for processing].
We will also receive information about you (including your personal information) if you use any other websites or apps operated or other services provided by us or our group companies. In this case, that information will be shared within the group and combined with information collected on this [website / platform/App].We will also receive and display information and content which you make publically available on your social media accounts.]
Some information is processed because you’ve given your consent to that (where consent is required). You can withdraw your consent at any time (in your account preferences or settings) or by contacting email@example.com
Sources of data
Your personal information is either (a) provided by you (e.g. via our website / platform / App /social media pages); (b) obtained from third parties (such as other entities in our group; (c) obtained from publicly available sources (e.g. the Internet, Companies House).
In particular, data may be obtained from the following third parties: galleries, social networks, payment processing companies, data brokers, ticketing companies, Google Adwords, Linkedin, Google Analytics, Adobe Analytics, display partners, social networks, 3rd party site plugins.
In some cases we need to collect or retain personal information for legal reasons
Some of the personal information we request is required to provide the services and if it is not provided, we may not be able to provide the relevant products and services to you or provide information you have requested from us. If the personal information is needed to participate in an activity on [our website / App/platform], you may not be able to do so if you do not provide that personal information to us.
In other cases, for example, when we request your personal data to send you marketing and promotional communications or to personalise your experience with our services, the lack of such information will mean it is impossible to send you these communications or to personalise your experience, but it will not have any consequence to the primary purpose of the data collection (to provide the services).
Any personal information you supply to us through [our website / platform/ App] must be complete and accurate. You also agree to allow us to contact you to verify your personal information, if we need to.
We generally keep information as needed to provide services and to deal with legal claims
We will keep your information for as long as it is reasonably necessary and to deal with claims. It will depend on factors such as whether you’ve got an account with us, have interacted with recent offers or have attended our recent events. We will also retain your information as necessary to comply with legal, accounting or reporting requirements.
We will also retain a copy of your contact details if you object or opt-out of receiving direct marketing communications from us. We will add your details to our suppression list to ensure you do not receive any future marketing communications from us. Also, we will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.
There are certain circumstances where we transfer your personal data to employees, contractors and to other parties.
- We share information about you with other members of our group of companies so we can provide the best service across our group. They are required to keep and use your information in accordance with this Privacy Notice. [insert specifics of group companies you share data with, if applicable]
- We will:
- share aggregated, anonymised or other de-identified data with advertisers, advertising networks and social networks that require the data to select and serve relevant adverts to you and others. We will also use aggregate information to help advertisers reach the kind of audience they want to target.
- make use of the personal information we have collected from you to help our advertisers display their advertisements to a target audience and to present our promotional messages to you including using Facebook Custom Audience. This means you will be presented with advertisements that are more relevant to you as a result of the personal information we hold about you.
- share your personal data with and access information from analytics and search engine providers that assist us in the improvement and optimisation of the website and the app and for better personalisation of content and advertising.
- We share your information with certain contractors or service providers. They may process your personal data for us, for example, if we use a marketing agency. Other service providers include advertising agencies, IT suppliers, database providers, backup and disaster recovery specialists, email providers and outsourced call centres. Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function. They will not be permitted to use your information for any purposes other than those outlined in this Privacy Notice.
- We also share your information with certain third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or services to you. These include [screening agencies and other partners we do business with such as other loyalty scheme partners. If we are not able to share information with certain partners who are also in our loyalty scheme, we will not be able to offer that service.
Your personal information may be transferred to other third party organisations in certain scenarios:
- if we discuss selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
- if we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you;
- if we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police;
- if we are defending a legal claim your information may be transferred as required in connection with defending such claim
- if there is an emergency including which requires us to share your data to protect the health and safety of our website’s or App’s users or the general public.
Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.
Where your information will be held
Your information may be transferred outside the European Economic Area.
The information that we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA), including the USA which does not have equivalent data protection laws to those applicable to Europe. It may also be processed by staff operating outside the EEA who work for us, for one of our affiliated companies, or for the organisation that hosts our [website / App/ platform].
However, to ensure your personal information is properly protected in line with EU data protection law, the transfer of this information is governed by a contract including Standard Contractual Clauses (SCCs) approved by the European Commission in accordance with Article 46(2)(c) of the General Data Protection Regulation.
We will only transfer data to jurisdictions outside the scope of the European General Data Protection Regulation (GDPR) where the appropriate safeguards set out in the GDPR are in place.
If you would like to obtain copies of the regulator-approved SSCs please contact us on the contact details below.
You have certain rights in relation to your information. The availability of these rights and the ways in which you can use them are set out below in more detail.
Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact firstname.lastname@example.org.
- Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal information. This enables you to receive a copy of the personal information we hold about you and certain other information about it.
- Correction: you are entitled to request that any incomplete or inaccurate personal information we hold about you is corrected.
- Erasure: you are entitled to ask us to delete or remove personal information in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.
- Restriction: you are entitled to ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Transfer: you may request the transfer of certain of your personal information to another party.
- Objection: where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Consent: where we are processing personal data with consent, you can withdraw your consentIf you want to exercise any of these rights, please contact [INSERT BUSINESS MARKETING OR INFO EMAIL ADDRESS]..
You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident where we are based or where an alleged infringement of Data Protection law has taken place. In the UK you can make a complaint to the Information Commissioner’s Office (Tel: 0303 123 1113 or at www.ico.org.uk).
Right to object
You have a right to object to us processing your information in certain circumstances.
Objection: where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.
As described above, you can opt-out of receiving direct marketing from us at any time.
We may use the information you give us on our website / App for direct marketing purposes to provide updates; newsletters; events; or other communications that we think may interest you. We will only do this with your consent (where required by law).
You can opt-out of receiving direct marketing from us at any time. You can do this by changing your marketing preferences on your online accounts settings page, clicking on the “unsubscribe” link included at the end of any marketing email we send to you, or by contacting email@example.com.
We use third party tools to personalise the advertising displayed to you on our website / App.
We use third party tools, to make the advertising we show you on our website, Apps and / or our partner websites more relevant and interesting to you,
You may opt-out at any time from the collection and use of your data by contacting us at [INSERT BUSINESS MARKETING/INFO EMAIL]..
Do Not Track
You can enable a ‘Do Not Track’ feature in your browser’s settings, if your browser supports that feature. When Do Not Track is turned on, your browser will send a Do Not Track request to the sites you visit. The Do Not Track request lets these sites know that you prefer not to have your browsing activity tracked. You can take similar steps in mobile.
To submit a Do Not Track request on mobile using an iOS device:
- launch the Settings app on your iPhone → Privacy → Advertising.
- toggle ON the switch next to Limit Ad Tracking.
- now that you have opted out of receiving ads targeted to your interests, based on your Apple ID on that device, you will be removed from the list of users receiving targeted ads.
To submit a Do Not Track request on mobile using an Android device
- open Google Settings,
- select AdsPrivacy.and toggle ON the switch next to Do Not Track to opt out of Ads Personalization. Do Not Track is now enabled on your Android device.
- Apps are then instructed not to use your advertising ID to build profiles or show you personalized ads.
Some devices may require a different procedure, so please check your instructions.
Cookies and Similar Technologies
Cookies collect and store information when you visit our website including information about how you use it through which it is possible to monitor your use of the website, as well as provide you with a better service and experience when browsing the website and for analytics.
Web beacons (also known as “single pixel GIFs”, “clear GIFs” or “tags”) are small graphic images that may be included on our website. Web beacons:
- allow us to optimise our products and services;
- provide us and third-party partners with analytics information, such as how many visitors our website receives; and
- are used by us in our email correspondence to determine whether you open them or take any further action.
We also work with other organisations to place our cookies and web beacons on their websites or in their advertisements. We do this to help us develop statistics on how often clicking on an advertisement on our websites results in a purchase or other interaction on the advertiser’s website.
The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal information, we cannot guarantee the security of your information transmitted through [our platform /App / website] and any transmission is at your own risk. Once we have received your personal information, we will use procedures and security features to try to prevent unauthorised access.
Links to third party website
Our website, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others including our partner networks, advertisers and other group companies and/or social networks as offered to you and supported by your browser.
The personal data that you provide through these websites is not subject to this privacy notice and the treatment of your personal data by such websites is not our responsibility. If you follow a link to any of these websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy notices of entities through which you choose to share.
We do not knowingly collect information from children or other persons who are under 18 years old. If you are under 18 years old, you may not submit any personal information to us or subscribe for the services. If you believe we might have any personal information from or about a person under the age of 18, please contact firstname.lastname@example.org.
Changes to this Notice
This notice may be changed from time to time.
If we change anything important about this notice (the information we collect, how we use it or why) we will highlight those changes at the top of the notice and provide a prominent link to it for a reasonable length of time following the change.
Once this notice is posted on our website, it will automatically come into force. The latest version of this notice will prevail over all previous versions.
If you would like to access previous versions of this notice please contact [INSERT BUSINESS MARKETING OR INFO EMAIL].
If you would like more information about the way we manage personal information that we hold about you, or are concerned that we may have breached your privacy and wish to make a complaint, please contact us as set out below. We will do our best to resolve your complaint.
If you have any questions about this notice please contact email@example.com.