Introduction
Welcome to the privacy policy ofINGENIUM
CONCEPTS LTD trading as Ingenium Academy.
Ingenium Academy respects your privacy and is committed to protecting
your personal data. This privacy policy will inform you as to how we
look after your personal data when you visit our website (regardless of
where you visit it from) and tell you about your privacy rights and how
the law protects you.
This privacy policy is provided in a layered format so you can click
through to the specific areas set out below. Alternatively, you can
download a pdf version of the policy here: [LINK]. Please also use the
Glossary to understand the meaning of some of the terms used in this
privacy policy.
1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED?]
4. [HOW WE USE YOUR PERSONAL DATA]
5. [DISCLOSURES OF YOUR PERSONAL DATA]
6. [INTERNATIONAL TRANSFERS]
7. [DATA SECURITY]
8. [DATA RETENTION]
9. [YOUR LEGAL RIGHTS]
10. [GLOSSARY]
1.
Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Ingenium Academy
collects and processes your personal data through your use of this
website, including any data you may provide through this website when
you sign up to our newsletter OR purchase a product or
service OR take part in a competition
OR
[OTHER EXAMPLE].
This website is not intended for children, and we do not knowingly
collect data relating to children.
It is important that you read this privacy policy together with any
other privacy policy or fair processing policy 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 privacy policy supplements other notices and privacy policies
and is not intended to override them.
Controller
INGENIUM CONCEPTS LTD trading as Ingenium Academy is the controller and
responsible for your personal data (collectively referred to as
["COMPANY"], "we", "us" or "our" in this privacy policy).
We have appointed a data privacy manager who is responsible for
overseeing questions in relation to this privacy policy. If you have any
questions about this privacy policy, including any requests to exercise
[your legal rights], please contact the data privacy manager
using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy
practices, please contact our [DPO ORdata privacy
manager] in the following ways:
Full name of legal entity:INGENIUM CONCEPTS LTD
trading as Ingenium Academy
Email address:legal@theingeniumapp.com
Postal address:69 - 75 Thorpe Road, Norwich, England,
NR1 1UA
You have the right to make a complaint at any time to the Information
Commissioner's Office (ICO), the UK regulator for data protection issues
(www.ico.org.uk). We would, however, appreciate the chance to deal with
your concerns before you approach the ICO so please contact us in the
first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last
updated February 2023.
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.
Third-party links
This website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may
allow third parties to collect or share data about you. We do not
control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to read
the privacy policy of every website you visit.
2.
The data we collect about you
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 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, maiden name, last name, username or
similar identifier, marital status, title, date of birth and gender].
-
Contact Data includes [billing address, delivery address, email address
and telephone numbers].
-
Financial Data includes [bank account and payment card details].
-
Transaction Data includes [details about payments to and from you and
other details of products and services you have purchased from us].
-
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].
-
Profile Dataincludes [your username and password,
purchases or orders made by you, your interests, preferences, feedback
and survey responses].
-
Usage Data includes [information about how you use our website, products
and services].
-
Marketing and Communications Dataincludes [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 could be derived from your
personal data but is not considered personal data in law as this data will
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 privacy policy.
We do not 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.
3.
How is your personal data collected?
We use different methods to collect data from and about you including
through:
-
Direct interactions . You may give us
your Identity, Contact and Financial Data by filling in forms or by
corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you [DELETE OR ADD TO THIS LIST AS
APPROPRIATE]:
-
apply for our products or services;
-
create an account on our website;
-
subscribe to our service or publications;
-
request marketing to be sent to you;
-
enter a competition, promotion or survey; or
-
give us feedback or contact us.
-
Automated technologies or interactions. As you interact
with our website, we will automatically collect Technical Data about
your equipment, browsing actions and patterns. We collect this personal
data by using cookies[, server logs] and other similar technologies. We
may also receive Technical Data about you if you visit other websites
employing our cookies. Please see our cookie policy [LINK] for further
details.
-
Third parties or publicly available sources. We will
receive personal data about you from various third parties [and public
sources] as set out below [DELETE OR ADD TO THIS LIST AS APPROPRIATE]:
Technical Data from the following parties:
(a) analytics providers such as Google based outside the UK;
(b) advertising networks [such as [NAME] based [inside
OR
outside] the UK]; and
(c) search information providers [such as [NAME] based [inside
OR outside] the UK].
-
Contact, Financial and Transaction Data from providers of technical,
payment and delivery services [such as [NAME] based [inside
OR
outside] the UK].
-
Identity and Contact Data from data brokers or aggregators [such as
[NAME] based [inside OR outside] the UK].
-
Identity and Contact Data from publicly available sources such as
Companies House and the Electoral Register based inside the UK.
-
[ANY OTHER WAYS WE COLLECT PERSONAL DATA].
4.
How we use your personal data
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 obligation.
Click here [LINK TO GLOSSARY, LAWFUL BASIS] to find out more about the
types of lawful basis that we will rely on to process your personal
data.
Generally, we do not rely on consent as a legal basis for processing
your personal data although we will get your consent before sending
third party direct marketing communications to you via email or text
message. You have the right to withdraw consent to marketing at any time
by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of 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.
Note that 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 to process your personal data where more than
one ground has been set out in the table below.
Purpose/Activity
|
Type of data
|
Lawful basis for processing including basis of
legitimate interest
|
To register you as a new customer
|
(a) Identity
(b) Contact
|
Performance of a contract with you
|
To process and deliver your order including:
(a)Manage applications, payments, fees and charges.
(b) Collect and recover money owed to us
|
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts
due to us)
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy
policy
(b) Asking you to leave a review or take a survey
|
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our
records updated and to study how customers use our
products/services)
|
To enable you to partake in a prize draw, competition or
complete a survey
|
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how
customers use our products/services, to develop them and
grow our business)
|
To administer and protect our business and this website
(including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data)
|
(a) Identity
(b) Contact
(c) Technical
|
(a) Necessary for our legitimate interests (for running our
business, provision of administration and IT services,
network security, to prevent fraud and in the context of a
business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|
To deliver relevant website content and advertisements to
you and measure or understand the effectiveness of the
advertising we serve to you
|
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
|
Necessary for our legitimate interests (to study how
customers use our products/services, to develop them, to
grow our business and to inform our marketing strategy)
|
To use data analytics to improve our website,
products/services, marketing, customer relationships and
experiences
|
(a) Technical
(b) Usage
|
Necessary for our legitimate interests (to define types of
customers for our products and services, to keep our website
updated and relevant, to develop our business and to inform
our marketing strategy)
|
To make suggestions and recommendations to you about goods
or services that may be of interest to you
|
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
|
Necessary for our legitimate interests (to develop our
products/services and grow our business)
|
Marketing
We strive to provide you with choices regarding certain personal data
uses, particularly around marketing and advertising. We have established
[a privacy centre where you can view and make certain decisions about
your personal data use: [PRIVACY CENTRE LINK]
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 and 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 third party for marketing purposes.
Opting out
You can ask us or third parties 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].
Where you opt out of receiving these marketing messages, this will not
apply to personal data provided to us because of a product/service
purchase, warranty registration, product/service experience or other
transactions.
Cookies
[You can set your browser to refuse all or some browser cookies, or to
alert you when websites set or access cookies. If you disable or refuse
cookies, please note that some parts of this website may become
inaccessible or not function properly. For more information about the
cookies we use, please see [LINK TO YOUR COOKIE POLICY
].
Change of purpose
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.
Please note that we may process your personal data without your
knowledge or consent, in compliance with the above rules, where this is
required or permitted by law.
5.
Disclosures of your personal data
We may share your personal data with the parties set out below for the
purposes set out in the table [Purposes for which we will use your
personal data] above.
ยท Internal Third Partiesas set out in the
[Glossary].
-
External Third Parties as set out in the [Glossary].
-
[Specific third parties [listed in the table [Purposes for which we
will use your personal data] above OR such as
[SPECIFIC THIRD PARTIES]].
-
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, then
the new owners may use your personal data in the same way as set out in
this privacy policy.
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.
6.
International transfers
[IF NO TRANSFERS OUT OF UK OCCUR:] [We do not transfer your personal
data outside the UK).
OR
[IF TRANSFERS OUT OF UK OCCUR:] We share your personal data within the
[COMPANY] Group. This will involve transferring your data outside the
UK.]
[Many of our external third parties are based outside the UK so their
processing of your personal data will involve a transfer of data outside
the UK.]
Whenever we transfer your personal data out of the UK, we ensure a
similar degree of protection is afforded to it by ensuring at least one
of the following safeguards is implemented [DELETE AS APPLICABLE]:
-
We will only transfer your personal data to countries that have been
deemed to provide an adequate level of protection for personal data. For
further details, see [ ].
-
Where we use certain service providers, we may use specific contracts
approved for use in the UK which give personal data the same protection
it has in the UK. For further details, see [ ].
-
[OTHER].
Please contact us if you want further information on the specific
mechanism used by us when transferring your personal data out of the UK.
7. Data security
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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably
necessary to fulfil the purposes we collected it for, including for the
purposes of satisfying any legal, regulatory, tax, accounting or
reporting requirements. We may retain your personal data for a longer
period in the event of a complaint or if we reasonably believe there is
a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data
are available in our retention policy which you can request from us by
contacting us.
By law we have to keep basic information about our customers (including
Contact, Identity, Financial and Transaction Data) for six years after
they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see
your legal rights
below for further information.
In some circumstances we will anonymise your personal 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws
in relation to your personal data. Please click on this
link
to the guidance from the Information Commissioner's Office below to find out
more about these rights:
-
Request access to your personal data.
-
Request correction of your personal data.
-
Request erasure of your personal data.
-
Object to processing of your personal data.
-
Request restriction of processing your personal data.
-
Request transfer of your personal data.
-
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact
usat legal@theingeniumapp.com.
No fee usuallyrequired
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 could 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 could take us longer than a month if your request is
particularly complex or you have made several requests. In this case, we
will notify you and keep you updated.
10. Website Privacy Policy
Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and
managing our business to enable us to give you the best service/product
and the best and most secure experience. We make sure we consider and
balance any potential impact on you (both positive and negative) and
your rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our
interests are overridden by the impact on you (unless we have your
consent or are otherwise required or permitted to by law). You can
obtain further information about how we assess our legitimate interests
against any potential impact on you in respect of specific activities by
contacting us.
Performance of Contract means processing your data where it is necessary
for the performance of a contract to which you are a party or to take
steps at your request before entering such a contract.
Comply with a legal obligation means processing your personal data where
it is necessary for compliance with a legal obligation that we are
subject to.
THIRD PARTIES
Internal Third Parties
The internal third parties in the Ingenium Academy community are
investors and investees.
External Third Parties
-
Service providers acting as processors based in [SPECIFIC COUNTRIES] who
provide [IT and system administration services].
-
Professional advisers acting as processors or joint controllers
including developers, lawyers, bankers, auditors and insurers based in
[SPECIFIC COUNTRIES] who provide consultancy, banking, legal, insurance
and accounting services.
-
HM Revenue & Customs, regulators and other authorities acting as
processors or joint controllers based in the United Kingdom who require
reporting of processing activities in certain circumstances.
-
[DETAILS OF ANY OTHER THIRD PARTIES, FOR EXAMPLE, MARKET RESEARCHERS,
FRAUD PREVENTION AGENCIES, PRICE COMPARISON SITES AND SO ON.]
YOUR LEGAL RIGHTS
You have the right to:
Request accessto 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 correctionof 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 erasureof 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 processingof 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 processingof your personal data.
This enables you to ask us to suspend the processing of your personal
data in the following scenarios:
-
If you want us to establish the data's accuracy.
-
Where our use of the data is unlawful, but you do not want us to erase
it.
-
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.
-
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 transferof 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 timewhere 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.