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Privacy Policy

1

Who we are

We are InConversation Media Limited, a company registered in England and Wales with company number 10437832, whose registered office is Rumwell Hall, Rumwell, Taunton, Somerset, England, TA4 1EL (the “Company” or “we” or “us”).

We are committed to lawful, fair and transparent processing of all personal information about our employees, customers, suppliers and other third parties during the course of our business activities. We will always comply with any applicable data protection legislation and we will ensure that collection and use of personal information is carried out in accordance with applicable data protection laws. The main law governing data protection is the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) known as the “GDPR”.

This policy sets out the basis on which we will process any personal information about you or individuals generally - whether it’s information we collect from those individuals or that is provided to us from other sources.

This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer or store personal information.

We are the controller of all personal information used in our business for our own commercial purposes. Sometimes though, we will process personal information on behalf of another data controller – and when this is the case, we will do so only in accordance with the instructions of that data controller and otherwise in accordance with the GDPR.

If we are processing on behalf of another data controller, that data controller will provide relevant information to you about how your data is being shared.

It is important that you read this policy, together with any other documents referred to in it, so that you are aware of how any personal information relating to you will be dealt with by us.

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Data protection principles

We are committed to demonstrating compliance with the GDPR’s six principles of processing personal information. These provide that personal information we deal with must be:

  1. processed fairly, lawfully and in a transparent manner.
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  3. adequate, relevant and limited to what is necessary.
  4. accurate and, where necessary, kept up to date.
  5. not kept for longer than necessary.
  6. processed securely, maintaining integrity and confidentiality.

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Definitions used in this policy

Personal information: In this policy, when we use the term “personal information” we mean any information relating to an identified or identifiable human being. (An “identifiable” natural person is one who can be identified, directly or indirectly, for example, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, biometric, mental, economic, cultural or social identity of that person.)

Sensitive personal information: In this policy, when we use the term “sensitive personal information” we mean special categories of information which are personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying someone, data concerning health or data concerning someone’s sex life or sexual orientation.

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The kind of personal information we hold about you

We may collect, record, organise, structure, store, adapt, alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, erase or destroy the following types of personal information about you:

We do not collect, store or use sensitive personal information.

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How is your personal information collected?

In the course of our business, we may collect personal information directly from an individual:

We will only collect personal information to the extent that it is required for the specific purpose notified to individuals about whom we are collecting it and/or as instructed by any data controller on whose behalf we are acting - and we will keep it only as long as is necessary.

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How we will use personal information

We will only use personal information when the law allows us to do so and relying on a relevant basis for lawful processing in each instance. We will use your personal information in the following circumstances, relying on the basis of processing indicated:

Basis of processing: Where we need to perform a contract we are about to enter into or have entered into with you.
Basis of processing: Where it is necessary for our legitimate interests (or those of a third party, such as a client using our services) and we have undertaken an assessment to determine that processing for those interests (listed below) does not outweigh your interests and fundamental rights, considering the nature and impact of the processing and any relevant safeguards we can put in place.
Basis of processing: Where we need to comply with a legal or regulatory obligation.
Basis of processing: Where you have consented to the processing.
Other issues about how we use personal information:

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Marketing & communications

As indicated above, we may use your personal information to provide you with information about goods and services which may be of interest to you and we may contact you about these by post, email, telephone or other digital channels such as social media.

Examples of marketing and/or communications may include:

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Consent

In this policy, where we have referred to needing your consent for any processing, we will make sure that the consent:

9

Data sharing

Transfer of personal information outside of the EEA:

We may transfer certain personal information that we hold on individuals living in the European Union to a country outside the European Economic Area ("EEA"), provided that one of the following conditions applies:

Subject to the requirements set out above, the personal information we hold may also be processed by individuals operating outside the EEA who work for us or for one of our suppliers. Those individuals may be engaged in, among other things, the fulfilment of contracts with the relevant individual, the processing of payment details and the provision of support services.

Safeguards: If we use a third party data processor to process personal information on our behalf, we will obtain contractual commitments to safeguard the security of the personal information to ensure that the third party only acts on our instructions when using that personal information and that the third party has in place appropriate technical and organisational security measures to safeguard the personal information.

Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We may also share personal information we hold with selected third parties for the purposes set out below.

Third party service providers who may process your personal information: When we use the term “third party”, we mean any entity who is not the Company, including third party service providers, contractors and designated agents and any member of our group. The third party service providers listed at Appendix A may have access to your personal information.

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Data security

We will always take appropriate technical and organisational measures to protect personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing (including taking reasonable steps to ensure the reliability of employees who have access to personal information). We protect user information by employing secure servers, firewalls, SSL encryption (where appropriate) and other technology. Our employees may only process personal information in accordance with this privacy policy, and any employee who breaches this privacy policy may be subject to disciplinary action, up to and including dismissal.

We have put in place internal procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

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Data retention

We will not keep personal information in a form which permits identification of individuals for longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required (or, where we are processing on behalf of another data controller, return their information to them).

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of personal information, the purposes for which we process information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will only keep personal information for as long as is necessary for the purpose or purposes for which that personal information is processed; and we will explain to anyone about whom we process data how long that is or the criteria that go into deciding how long that is. We will anonymise your personal information (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.

Our website may, from time to time, contain links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or the security of these websites. Please check the relevant policy before you submit any personal information to these websites.

12

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information, as summarised below.

You have the right to:

If you wish to exercise any of the rights set out above, please contact us at info@inconversation.net. We aim to respond to all legitimate requests within one month (and if we are only processing the data in question on behalf of another party, the response may actually come from that other party as the relevant data controller). 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.

You will not have to pay a fee to access your personal information (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.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

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Cookies

Our websites use cookies to distinguish you from other users of our website for the purpose of visitor tracking via the Google Analytics platform. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device if you agree.

Cookies contain information that is transferred to your computer or device.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you block cookies you may not be able to access all or parts of our website.

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Data Protection Officer

The person nominated to oversee how the Company deals with personal information, our Data Protection Officer, is responsible for ensuring compliance with GDPR and with this policy. This post is held by David Dobrin, david@inconversation.net.

Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to this person.

15

Changes to this policy

We reserve the right to change this policy at any time. Where appropriate, we will notify individuals (or the relevant data controller, in respect of any personal information provided to us for processing on their behalf) of those changes by post or email. Each time you enter or use our website, you agree that the privacy policy current at that time shall apply to all information we hold about you. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

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Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@inconversation.net.