IMRG Limited (“IMRG”) is a membership organisation for online retailers providing resources and services for its members and other parties in the retail industry (together the “Services”). For more information please see About us.
Although our members are businesses, not individuals, we do collect and use personal information relating to individuals as part of our activities. This is generally in order to manage our membership and to carry out our wider work providing resources and information to online retailers in the UK. We also collect personal information about individuals who sign up to our events, surveys, information or subscription services, or to receive our briefings. We also collect data on other individuals we work with.
We have appointed a data privacy manager 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 Data Privacy Manager by email at [email protected] or by post at IMRG Marlborough House, 10 Earlham Street, London, WC2H9LN
We are a data controller in respect of the personal data we collect and for the registered on the Information Commissioner’s Office Register registration number ZA084392.
1. How we collect your data
2. Information we may collect about you
3. Use of your information
4. Contacting you
5. Our legal basis for collecting, holding and using your information
6. Sharing your information
8. International transfers
9. Security and storage of your information
10. Data security
11. Data retention
12. Your rights
HOW WE COLLECT YOUR DATA
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).
Information you give to us. You may give us information about you by filling in an online form, contacting us by phone or e-mail or in person. This includes information you provide if you complete a membership form on behalf of a business, if you register to attend one of our events or sign up to our newsletter or other information and subscription services. You may also give us your information if you complete an application form or otherwise apply for a job here, either directly, or via a third party.
Information we receive from other sources. We work closely with other organisations, such as business partners, sub-contractors, analytics providers, search information providers, and we may receive information about you from them.
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.
INFORMATION WE MAY COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, company name, phone number, username or similar identifier, title and email address.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website and Services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
USE OF YOUR INFORMATION
We need to obtain, store and use information about you for legitimate business purposes – namely so that you can enjoy and benefit from our Services. We may use information we hold about you in the following ways:
- to confirm your identity
- to send you our newsletters and data and analysis from our retail index
- to administer the membership of your company/organisation
- to let you know about other relevant services (see the section below on ‘Contacting you’ for more information about this)
- to update and correct our membership records
- to carry out statistical and market analyses, including benchmarking exercises, to enable us to understand you better and improve our services
- to develop, test and improve our systems
- to notify you about changes to our services
- to ensure the content of our website is presented in the most effective manner for you and for your computer
- to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
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.
An important part of our work is communicating with our membership, so we use personal information to keep in touch with individuals within our member organisations, as well as partners and other individuals.
We will use the contact information you have given us to send you important information. This may be by post, email, text message or telephone.
We may also use the information we hold about you, in order to provide you with information about our other products or services we feel may interest you.
Because we operate primarily with businesses rather than individuals, we do not generally seek your consent to send you marketing communications. We believe that such communications are both in our legitimate interests, to raise awareness of our work and promote our services, and in your interests to receive information about the retail index, webinars and events that benefit you and your business.
However, you can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
OUR LEGAL BASIS FOR COLLECTING, HOLDING AND USING YOUR INFORMATION
Data protection law sets the lawful legal bases (or ‘conditions’) which allow us to collect, hold and use your personal information. For IMRG, these are:
- For the purposes of our own legitimate interests. We believe that we have a legitimate interest in being able to provide our services to our member organisations in the UK. As set out in this notice, this sometimes requires us to collect and use personal information about individuals. We only use this legal basis where these interests are not overridden by your interests and fundamental rights and/or freedoms.
- Where we have entered into a contract with you. In these circumstances, we may need to process your personal information in order to fulfil the contract. For example, this may apply if you book to attend one of our events.
- Where we are under a legal obligation to process personal information. For instance, we are required to collect certain information in accordance with our obligations under equalities legislation.
- Sometimes, we will ask you for your agreement to process your personal information. This is particularly the case when we wish to collect or use any special categories of personal information (see below).
Data protection law recognises certain “special categories” of personal information, which include information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information for uniquely identifying a person, information concerning health, and information concerning a person’s sex life or sexual orientation. These special categories are considered particularly sensitive and so we will only collect and use this information where you have given us your explicit consent or where we consider it necessary to do so. For example, you may choose to tell us about your health condition before attending one of our events. We will only use this information for the particular event or campaign and not for any other purposes.
SHARING YOUR INFORMATION
We may share your information with selected third parties including:
- Event venues, attendees, speakers, sponsors and organisers contracted by IMRG
- Online service providers such as event booking systems, marketing systems and survey tools
- Professional cloud services and technology providers such as hosting providers, CRM providers and other professional cloud services which allow us to provide our Services
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 and in accordance with our instructions.
Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page. Cookies serve many functions, for example, they can help us to remember your username and preferences, analyse how well our website is performing and allow us to send you content that we believe will be most relevant to you.
We use the following types of cookie:
Some cookies are essential for the operation of our website and allow us to identify IMRG members, so we can ensure they can access the member-only pages. If a member opts to disable these cookies, the member will not be able to access all of the content that a membership entitles them to. By accepting the use of login functionality, you must agree to the setting of specific cookies which allow these areas to function
We utilise other cookies to analyse how visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customising our offering and quickly identifying and fixing any issues that arise. From tracking the most popular pages to finding out why some pages are receiving error messages, we use these cookies to highlight articles or site services that we think will be of interest to you based on your usage of the website.
Functionality cookies allow us to remember your preferences. Cookies save you the trouble of typing in your username every time you access the site, and recall your preferences, such as which sections of the website you want to see when you log in.
IMRG also use third party cookies such as Google Analytics to help us monitor our website traffic. These third party cookies may help us with market research, revenue tracking, improving site functionality and monitoring compliance with our terms and conditions and copyright policy. For example, surveys or comparisons may be added by third parties as added functionality. We will endeavour to ensure full disclosure of any cookies from third party websites.
Some of our Third Parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data 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 will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
• Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 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.
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.
By law we have to keep basic information about our customers for six years after they cease being customers. In some circumstances you can ask us to delete your data and please see below for more information.
In some circumstances we may anonymise your personal data and company 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.
YOUR LEGAL RIGHTS
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. Note that 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.
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.