Privacy policy

Ithina respects your privacy and is committed to protecting your personal data. This Policy tells you how we look after your personal data when you visit our website (regardless of where you visit it from), use our apps, sign up for our services or register interest in an Ithina event, and tells you about your privacy rights and how the law protects you. This Policy is applicable to all Ithina websites and marketing.

This Policy applies to Ithina and any entities doing business under the Ithina name worldwide which collect, process and/or store information. It outlines how we gather and use information that you share through our websites and apps, or when you sign up for our services, agree to provide services to us or register interest in an Ithina event.

It is important that you read this Policy 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 Policy supplements any other notices and is not intended to override them. Please read this Policy carefully before you provide us with any data. By using our websites, our services, providing services to us or registering for our events, you consent to the collection and use of your details as explained in this Policy.

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.

If you have any questions, requests or concerns about the way we collect and use your details, please get in touch using the contact page.

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 collect information about you or your devices using the following sources and methods:

Direct interactions

You may give us your Identity, Contact and Financial Data by filling out forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Apply for our products or services
• Create an account on our website
• Subscribe to our service or publications
• Supply products or services to us
• Request marketing to be sent to you
• Provide us with your business card
• Enter a competition, promotion or survey
• Give us some feedback
• Attend an Ithina event

Automated technologies or interactions

As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. Please see the section on cookies and other data collection technologies below.

Third parties or publicly available sources

Information received from the Ithina corporate family in the ordinary course of business, and data from third parties (including publicly available directories) as part of Ithina’s marketing and new business initiatives.

• Identity Data includes first name, last name, title, professional details, and information relevant to event attendance, e.g. dietary requirements.
• Contact Data includes telephone numbers, email address, billing address and delivery address.
• Financial Data includes bank account details and credit searches.
• Transaction Data includes details about payments to and from you and other details of the products and services you have purchased from us or we have purchased from you.
• Technical / Automatically Collected Data includes internet protocol (IP) address, browser type and version, time zone setting and location, search keywords, browser plug-in types and versions, operating system and platform, device identifiers, geolocation, internet connection information and other technology on the devices you use to access our websites.
• Profile Data includes your purchases and orders made by you or orders we have placed with you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our websites, products and services.
• Marketing and Communication 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 Policy.

Ithina does not seek to collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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 goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

We use technologies to collect information about your activities on Ithina websites.

Cookies and local storage objects are files that contain data, such as unique identifiers, that we or a third party (e.g. Lead Forensics, HubSpot, Google Analytics) transfer to or read from your device to recognise the device, provide services, keep records, and conduct analytics and marketing. We and third parties use automated means to read or write information on your devices. These include various types of cookies and other browser-based or plugin-based local storage (such as HTML5 storage or Flash-based storage).

You may choose to set your web browser to disallow certain types of cookies or to send you an alert when specific types of cookies are being sent. Some browsers offer similar settings for HTML5 local storage and Flash storage. If you block or otherwise reject our cookies or local storage, certain websites (including our own) may become inaccessible and not function properly. For instructions on rejecting or deleting cookies, please visit www.allaboutcookies.org.

Ithina also uses other standard automated technologies, such as web beacons (also called clear GIFs or pixel tags) or similar technologies, to deliver or communicate with cookies and track your use of our websites and/or apps. We include web beacons in email messages to track whether you open the messages, as well as for other uses (see the purposes described below).

Occasionally, we facilitate the collection of information by advertising services administered by third parties. The ad services track your online activities over time by collecting information through automated means, e.g. cookies. They use this information to show you ads tailored to your interests or characteristics and/or based on past visits to particular sites or apps, or other information we know, infer or have gathered from you.

Ithina, and third-party vendors (such as Lead Forensics, HubSpot and Google Analytics, based outside the EU), use first and third-party cookies together, as well as other automated means and other data, to:

• Identify you and your devices
• Inform the creation, optimisation and deployment of ads
• Create reports on ad impressions, other uses of ad services, and interactions with ad impressions and ad services (including their relation to visits to certain sites and/or apps)

If you wish to opt out from the targeting of internet-based ads, please get in touch through the contact page. You can also adjust your preferences related to advertising and analytics services offered by Google at google.com/settings/ads/onweb#display_optout and tools.google.com/dlpage/gaoptout. You may need to use these opt-out tools again if you replace, change or upgrade your browser, or delete your cookies.

To use any additional privacy controls offered by your mobile operating system (e.g. privacy settings for device identifiers and geolocation), please visit your mobile device manufacturer’s website.

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

The table below describes all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on where more than one ground is set out.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms.

Promotional offers 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 products, 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 goods or services from us, or if you provided us with your details when you gave us your business card, entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third party marketing

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

Some third parties’ embedded plugins or other automated technology on our websites, such as cookies or social sharing buttons, allow their operators to know that you have visited or interacted with our websites. They combine this information with other, identifiable information they have collected about your visits to other websites or online services. These third parties handle this information, and other information they directly collect through their content and plugins, under their own privacy policies.

Ithina believes it is important that you have a say in how your information is used. We use your data as described in this Policy. If we wish to use your information in a way that has not been outlined in this Policy, we will first secure your consent.

We may have to share your personal data with the parties set out below for the purposes set out in the table above:

• Ithina group companies
• Ithina-appointed third party suppliers, partners, resellers and distributors involved in the provision of goods or services to you or to Ithina
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this Policy
• Tax authorities, regulators and other authorities
• Credit reference agencies

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 specified purposes in accordance with your instructions.

You may not wish to receive marketing communications from us, or you may wish to tailor which communications you receive. We will always respect your preferences. To edit your preferences, please get in touch through the contact page.

You can also opt out of marketing emails at any time by using the unsubscribe links at the bottom of Ithina marketing emails.

Ithina will not sell or share your information with third parties (other than our subsidiaries or affiliates and our partners, including resellers and distributors).

Please see the section on cookies and other data collection technologies, which describes other ways you can exercise your opt-out rights.

Ithina guards against unauthorised access by implementing administrative, technical and physical security measures. Despite these measures being in place, no internet data transmission can be completely secure. Ithina cannot and does not guarantee or warrant the security of any data you transmit via our websites.

Ithina takes measures to restrict access to information to only those employees, contractors, partners and agents who require access to operate, develop, enhance or deliver our content, products and services.

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 when we are legally required to do so.

Ithina works on a worldwide basis. Your data might be passed to an international office outside the country where you are located. Depending on your country of residence, when you provide information to us, we may transfer that information to our facilities in other countries. The recipients of the information disclosures described above (“Purposes for which we will use your personal data”) may be located in your country or elsewhere in the world.

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK, for example:

• with our offices or other companies within our group located outside the UK;
• with your and our service providers located outside the UK;
• if you are based outside the UK;
• where there is a European and/or international dimension to the services we are providing to you.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK where:

• the UK government has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
• a specific exception applies under data protection law.

Adequacy decision

We may transfer your personal data to certain countries on the basis of an adequacy decision. These include:

• all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
• Gibraltar; and
• Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects. The safeguards will usually include using legally-approved standard data protection contract clauses.

Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, for example where:

• you have explicitly consented to the proposed transfer after having been informed of the possible risks;
• the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
• the transfer is necessary for a contract in your interests, between us and another person; or
• the transfer is necessary to establish, exercise or defend legal claims.

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

Further information

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Ithina will only keep information for so long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. Data may persist in copies made for backup and business continuity purposes for additional time.

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.

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. 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 through the contact page.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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.

Questions

Please get in touch if you have any questions about this Policy, or about how Ithina collects and uses your data.

Complaints

If you wish to make a complaint about our adherence to this Policy, please get in touch through the contact page. You may need to provide proof of identity.

If you are a UK data subject and your complaint is not resolved after discussing the matter with us, we will help cooperate with the relevant UK privacy regulator to resolve the matter. You will not be charged.

If you live outside the UK and wish to make a formal complaint about Ithina’s data protection practices, please contact the relevant data protection authority in your country.

To keep you informed, we sometimes share links to other websites or resources that are not associated with the products or services provided by Ithina.

We have no control over these websites or their privacy standards. Any information you share via these sites is subject to those sites’ privacy policies.

Ithina offers business-related content that is designed to be consumed by adults only. We do not knowingly collect information from or about children (people under the age of 18 years).

We may change or update this Privacy Policy in line with changes in the law, our information handling practices, or the functionality of our services or website. The latest, updated Privacy Policy will be posted on our website. If we make substantial changes to our Policy, we will inform you by posting a more prominent notice.