Privacy Policy

1. IMPORTANT INFORMATION ABOUT THIS POLICY

Iceotope Technologies Limited (“Iceotope”, “we”, “us” and “our”) collects, uses and stores (collectively referred to as “processes”) information about individuals (“personal information”), including visitors to our website: www.iceotope.com (“Website”), customers, prospective customers, suppliers, business partners, job applicants and visitors to our premises (“you”, “your”).  The purpose of this privacy policy (“policy”) is to: (i) make you aware of what personal information we will hold, how and why your personal information will be used, and how long it will be retained for, and (ii) provide you with certain information that we are required to notify you of under the UK data protection laws.

Please read this policy carefully as it explains how we use personal information. We keep this policy under regular review and may change this policy and, when we do, we update this page, so please check back frequently.

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, for example a new address or email address.

We are what is known as the ‘Controller’ of the personal information you provide to us, and our contact details are: privacy@iceotope.com. If you have any questions about this policy, including any requests to exercise your legal rights, please contact us at info@iceotope.com.

2. WHAT PERSONAL INFORMATION WE PROCESS

Personal information (also referred to as “personal data”) means any information describing or relating to an identified or identifiable individual. We collect and process various types of personal information about you, which we have set out in the table below, for the purposes set out in this policy:

Personal and Contact Details

• Name
• Job title
• Company name of employer
• Business email address

Technical Information

• Internet protocol (IP) address
• Login data
• Browser type and version
• Time zone setting and location
• Browser plug-in types and versions
• Operating system and device type (and ID)
• Display settings
• Session start/stop time
• Referral URL
• Time zone
• Network connection type
• Geo-location address

Usage Information

• User ID, session ID, and campaign data
• Tracking data of page views, sessions, and user journey across our website
• Website traffic analytics and user engagement data

Apart from personal information relating to you, if you provide us with the personal information of any third parties, before you provide such third-party personal information to us, you must first inform these third parties of any such information which you intend to provide to us and of the processing that we will carry out, as detailed in this policy.

We also collect and use aggregated data such as statistical or demographic data which is not personal information as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our websiteb to help improve it and our service offering.

3. HOW WE COLLECT PERSONAL INFORMATION 

We use different methods to collect information from and about you including through:

Your interactions with us

You may give us your personal information by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal information provided you provide when you:

• Purchase our products and/or services;
• Provide us with products and/or services;
• Request marketing to be sent to you;
• Attend an event (e.g. webinar, conference (whether in person or remotely)
• Give us feedback or contact us, make enquiries, requests or complaints.

Automated technologies or interactions

As you interact with our Website, we will automatically collect Technical Data and Usage Data (further details of which are set out above).

We collect this personal information by using cookies and other similar technologies. Please see our Cookie Policy for further details.‍

4. HOW WE USE PERSONAL INFORMATION AND OUR LAWFUL BASIS FOR PROCESSING IT

Whenever we process your personal information we do so on the basis of a lawful basis or justification for that processing. Processing of sensitive personal information is always justified on the basis of an additional lawful basis.

In most cases, we rely on one or more of the following lawful bases:

• Performance of a contract with you: where the processing is necessary to perform the contract we are about to enter into or have entered into with you.
• Legal obligation: where the processing is necessary for compliance with a legal obligation that we are subject to.
• Legitimate interests: where the processing is necessary for our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information. 

In exceptional circumstances we may carry out processing based on your consent. Where we rely on consent, we will make it clear at the time.

We have set out below, in a table format, a description of all the ways we use your personal information, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are (where appropriate).

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5. MARKETING

You will receive marketing communications from us if you have requested information from us (such as a white paper or fee quote), purchased products or services from us, or not opted out of receiving the marketing. 

You can ask to stop sending you marketing communications at any time by following the unsubscribe links within any marketing communication sent to you or by contacting us via the contact details provided below. It may take up to 14 days for your change in preference to take effect and the change will not affect any marketing emails which have already been scheduled to be sent in the future. If you opt out of email marketing, we may still need to send you service communications by email occasionally, such as information about changes to our services.

We may also analyse your Personal and Contact Details, Technical Information and Usage Information to form a view which of our products and services may be of interest to you so that we can then send you relevant marketing communications.

For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy.

6. DISCLOSURES OF YOUR PERSONAL INFORMATION

Within Iceotope, personal information is shared internally on a need-to-know basis with our staff and personnel including directors, shareholders, employees, contractors and other temporary workers.

Depending on your dealings with us, we may share some or all of the personal information set out in section 2  where necessary with the following third parties for the purposes set out in section 4:

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We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

7. INTERNATIONAL TRANSFERS

We may transfer your personal information to service providers that carry out certain functions on our behalf. This may involve transferring personal information outside the UK to countries which have laws that do not provide the same level of data protection as the UK laws.

Whenever we transfer your personal information out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place (as applicable):

• We will only transfer your personal information to countries that have been deemed by the UK to provide an adequate level of protection for personal data.
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal information the same protection as it has in the UK, namely The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us at the contact details set forth below.

8. DATA SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

9. HOW LONG WE RETAIN PERSONAL INFORMATION 

We will only retain your personal information 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. However, some personal information may be retained for varying time periods to comply with legal and regulatory obligations and for legitimate business reasons. We may retain your personal information 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 information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your personal information: see “Your Legal Rights” below for further information.

10. YOUR LEGAL RIGHTS 

Depending on the circumstances, you have a number of rights under data protection laws in relation to your personal information.

You have the right to:

• Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information 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 information in certain circumstances. This enables you to ask us to delete or remove personal information 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 information 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 information 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 information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your information (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see section entitled “Marketing” for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information 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.
• (where applicable) Withdraw consent at any time where we are relying on consent to process your personal information (see the table in section 4 for details of when we rely on your consent as the legal basis for using your 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.
• Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in one of 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; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us at the contact details provided in section 11.

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 could 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 you for further information in relation to your request to speed up our response.

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 a number of requests. In this case, we will notify you and keep you updated.

11. CONTACT DETAILS

If you have any questions about this policy or about the use of your personal information or want to exercise your privacy rights, please contact us at: privacy@iceotope.com

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.

12. THIRD PARTY LINKS

Our 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.

13. YOUR UNITED STATES PRIVACY RIGHTS

Certain US States, such as California, Colorado, Connecticut, Texas, Utah, Virginia and other states, have comprehensive privacy laws (“US State Privacy Laws”) which provide residents of such states with the rights listed below regarding their personal data, subject to applicable law. The categories of personal information we process, our purposes for processing your personal data, the categories of personal data that we share with third parties and the categories of third parties with whom we share it are detailed above in this Privacy Policy.

The US State Privacy Laws provide you with the following additional rights:

• Right to know. You have the right to know and see what personal data we have collected about you. If you are a resident of Delaware, you also have the right to obtain a list of the categories of third parties to which we have disclosed personal data of Delaware residents.
• Right to data portability. You have the right to obtain a copy of your personal data that you previously provided to us in a portable and, when feasible, readily usable format, where the processing is carried out by automated means. You may request such personal data up to twice annually, subject to certain exceptions.
• Right to delete. This is similar to the right of erasure provided in the “Your Legal Rights” Section above and has similar carve-outs, including to comply with applicable law.
• Right to opt out of selling or sharing. You have the right to opt out of the sale of your personal data and/or the processing of your personal data for purposes of (i) targeted advertising or (ii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, unless you reside in Iowa or Utah. As of the latest date of the Privacy Policy:
  • We DO NOT process personal information for the purposes of targeted advertising;
  • We DO NOT “sell” your personal information as the term is broadly defined under State Privacy Laws (however, we do not monetize your personal information); and
  • We DO NOT engage in profiling decisions based on your personal information that produce legal or similarly significant effects concerning you.

• Right to correct. You have the right to request that we correct inaccurate personal data.
• Right to nondiscrimination. You have the right not to receive discriminatory treatment by us for the exercise of your rights under US State Privacy Laws. Unless permitted by US State Privacy Laws, we will not:
  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

• Exercising Your US State Privacy Law Rights

To exercise any of your rights under US State Privacy Laws, or if you have any questions about your privacy rights, you may contact us by emailing privacy@iceotope.com.