1. IMPORTANT INFORMATION ABOUT THIS POLICY
2. WHAT PERSONAL INFORMATION WE PROCESS
3. HOW WE COLLECT PERSONAL INFORMATION
4. HOW WE USE PERSONAL INFORMATION AND OUR LAWFUL BASIS FOR PROCESSING IT
6. DISCLOSURES OF YOUR PERSONAL INFORMATION
9. HOW LONG WE RETAIN PERSONAL INFORMATION
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.
We have designed this policy to make it easier for you to navigate the information contained within it and locate the information that is most relevant to you. We include an index of contents below with clearly worded headings so you can quickly and easily find the information you are looking for by clicking on the relevant heading.
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 via at this email address.
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 · Business telephone/mobile numbers · Business address · (Where a visitor, for car parking purposes) Vehicle registration number and model of vehicle
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Recruitment Information |
· Relevant Personal and Contact Details (including residential address, personal email, telephone and/or mobile number) · Data of birth · Identification information · Details of your qualifications, experience and education, and CV · Current / desired salary · Employment history · Interview notes/information · References · Vetting / verification information · Information relating to immigration and right to work (including VISA information (where applicable), passport, residency, work permits) · Details of any disability and any reasonable adjustments required as a result · Information related to the outcome of your application · Any other personal information which you chose to disclose to us during the recruitment process whether verbally or in written / electronic form
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Technical Information |
· Internet protocol (IP) adress · 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
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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
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To the extent permitted by applicable laws, we collect and process a limited amount of personal information within the above-mentioned information falling into special categories of personal information often referred to as “sensitive personal information” for the purposes set out in section 4 below. For example, special category personal data about your health to provide appropriate adjustments or accommodations where appropriate in the event you choose to disclose that you have a disability.
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, use and share 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 Website to help improve it and our service offering.
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; · Subscribe for our white papers; · Request marketing to be sent to you; · Attend an event (e.g. webinar, conference (whether in person or remotely)); · Apply for a job with us during the recruitment process; or · Give us feedback or contact us, make enquiries, requests or complaints.
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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.
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Where you apply for a job with us |
During the recruitment process, as well as obtaining information directly from you, we also obtain information from third parties, for example, references from previous employer, information from recruitment consultants. Some information may be obtained from publicly accessible sources. If information is required by the contract or statute this will be indicated at the time of collection.
We will let you know where there are consequences of you not providing the information requested. Failure to provide some information will mean that we cannot continue with the recruitment process as we will not have the personal information, we believe to be necessary for the effective and efficient administration of the recruitment process.
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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).
Purpose/Use |
Type of personal information |
Lawful basis for processing |
To provide our products and services which includes processing orders, sending invoices and payment reminders, collecting payments / debts owed to us and any other general contract administration
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Personal and Contact Details
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The processing is necessary for the performance of a contract (“performance of a contract”).
Additional processing is necessary for our legitimate interests (to recover debts due to us) (“necessary for our legitimate interests”).
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To manage our relationship with you which will include dealing with your enquiries, requests, complaints and queries |
Personal and Contact Details |
The processing is necessary for the performance of a contract.
Additional processing is necessary for our legitimate interests to respond to any correspondence or queries you send us.
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To send: (i) relevant marketing communications about our products and services and any relevant marketing events, including online webinars, conferences, and (ii) other related information, including solicited information (such as fee quotes in response to an enquiry)
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Personal and Contact Details
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This processing is necessary for our legitimate interests to carry out direct marketing, develop our products and services and grow our business.
Where information is solicited, consent.
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To administer and protect our Website and deliver material to our Website. For example: manage user sessions and authentication for secure access, and ensure website security by preventing cross-site request forgery (CSRF) |
Technical Information
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Necessary for our legitimate interests to run our business effectively, improve, develop and protect our Website.
Where we rely on consent where personal information is collected for the above-mentioned purposes via a cookie used on our Website.
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To use data analytics to improve our Website, products and services, customer relationships and experiences and to measure the effectiveness of our Website, communications and marketing. Examples include: · store user preferences and settings to enhance user experience, · distribute web traffic across servers for optimal performance, · recognise returning users to provide a personalized experience, · track visitor and prospect activities on our Website and landing pages, · assist in lead generation and marketing automation, · identify returning visitors for a seamless user experience, · measure the effectiveness of marketing efforts and campaigns.
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Technical Information
Usage Information
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This processing is 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. store information on user interactions and preferences for targeted content delivery,
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When you subscribe to receiving our white papers via our Website, contact us via email, phone, or contact us via the Contact Us page on our Website
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Personal and Contact Details |
This processing is necessary for our legitimate interests to respond to messages / enquiries, manage our customer service relationships, monitor and maintain our service standards, assist staff training and for fraud prevention and compliance activities.
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When you provide us with products and/or services (including support, maintenance and other associated services) including ordering and making payments, and any other general contract administration
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Personal and Contact Details |
The processing is necessary for the performance of our contract with you.
We also process certain information to comply with legal obligations to which we are subject, such as with respect to tax.
Additional processing is necessary for our legitimate interests in conducting our business, including ordering and paying for products and/or services and good contract management.
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Recruitment and selection to consider your suitability for the role you applied for, comparing you to other candidates and making recruitment decisions
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Personal and Contact Details
Recruitment Information |
Some of this processing is necessary for the compliance with legal obligations to which we are subject including the requirement to make reasonable adjustments or accommodations where appropriate in the event you choose to disclose that you have a disability.
Some of this processing is necessary for taking steps at your request to enter into a contract with you.
Additional processing is necessary for our legitimate interests in fully assessing job candidates to ensure that only suitable and appropriate candidates are selected, to compare candidates and make fair decisions on the most appropriate candidate for the role.
We aim to recruit the best individual for each vacancy through fair, effective recruitment and selection procedures. This contributes to us continuing to meet our business objectives, maintain our reputation and attract high calibre employees.
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Pre-employment checks including (as appropriate) identify check, right to work verification, reference check, and any other verification required regards previous employment history, professional and educational qualifications |
Recruitment Information |
Some of this processing is necessary for the compliance with legal obligations to which we are subject including establishment of the right to work.
Additional processing is necessary for our legitimate interests in ensuring that candidates for employment (or engagement) do not pose an unacceptable risk to our business and we consider such checks are necessary to detect and prevent crime and other unlawful acts and protect our business from fraud, dishonesty or incompetence.
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Offers of employment and on-boarding including making job offers, providing contracts of employment (or engagement) and preparing to commence your employment (or engagement) with us
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Personal and Contact Details
Recruitment Information |
Some of this processing is necessary for the compliance with legal obligations to which we are subject including the requirement to issue written particulars or terms of employment and the requirement not to unlawfully discriminate in the terms of any offer to you.
Some of this processing is necessary for taking steps at your request to enter into a contract with you.
Additional processing is necessary for our legitimate interests in ensuring the effective employment (or engagement) of staff on appropriate terms and conditions of employment (or engagement), which will contribute to us continuing to meet our business objectives, maintain our reputation and attract high calibre employees.
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In connection with any merger, sale, transfer of our assets, investment, acquisition, bankruptcy or similar event or corporate transaction
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Potentially all types of personal data |
This processing is necessary for our legitimate interests to ensure we can protect and grow our business. |
Complaints, claims and litigation to enforce our legal rights and obligations, and for the purposes in connection with any complaint or legal claim made against us
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Potentially all types of personal data |
This processing is necessary for our legitimate interests in protecting Iceotope from breaches of legal obligations owed to it and defending itself against litigation. It is important to protect our business from damage or loss to ensure its continued success and growth. |
Legal or regulatory disclosures to comply with lawful requests by public authorities (including law enforcement), discovery requests, or where otherwise required or permitted by applicable laws, court orders, governmental regulations or regulatory authorities
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Potentially all types of personal data |
This processing is necessary to comply with our legal obligations where there is a legal obligation to disclose information or a court or legal order to provide information.
Where not legally required, necessary for our legitimate interests in co-operating with relevant authorities, government bodies or regulators for the provision of information where appropriate. We wish to maintain our reputation as a good corporate citizen and to act ethically and appropriately.
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Types of sensitive personal information we process, the purposes we use it for and the additional lawful basis that applies
We have identified the following purposes for collecting and processing sensitive personal information and these are set out in the table below together with the additional lawful basis we rely on in each case:
Purpose/Use |
Type of personal information |
Lawful basis for processing |
Pre-employment checks including (as appropriate) identify check, right to work verification, reference check, and any other verification required regards previous employment history, professional and educational qualifications |
Recruitment Information including documentation such as work permits, VISAs, details of residency, proof of citizenship will be processed to assess and review eligibility to work for Iceotope
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This processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or Iceotope in the field of employment law, social security and social protection law, to the extent permissible under applicable laws, in particular, the requirement to check that you are legally permitted to work in the UK. |
Health and medical data may be used to comply with employment, health and safety or social security laws, e.g. to make reasonable accommodations or adjustments, avoid unlawful discrimination or dealing with complaints arising in this regard
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Recruitment Information |
This processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or Iceotope in the field of employment law, social security and social protection law, to the extent permissible under applicable laws. |
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.
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:
Category of recipients |
Details of disclosure |
External |
We engage third party service providers, suppliers and vendors from time to time (some as our processors) to: · IT service providers to help us manage our IT and back-office systems. · Data and website service providers including web hosting, storage and web analytics. · Payment and invoicing platforms. · Analytics and search engine providers to help us improve and optimise our products and services. · Recruitment agencies to help us locate suitable candidates for vacancies. · (where you attend an event hosted or sponsored by us) event organisers and logistics companies in connection with the event. · Sub-contractors, suppliers or service providers engaged by us to deliver a product or service what we have instructed them on or assist with customer management. · Professional advisors such as tax and legal advisors. |
External |
We may disclose personal information if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process (including to law enforcement or competent authorities like the policy and tax authorities). |
External |
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Some or all personal information set out above may be disclosed in the case of a corporate transaction. 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 information in the same way as set out in this policy. |
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.
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 law.
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 out in section 11 below.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised 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.
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 in order 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 unauthorised 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 section 10 below for further information.
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 (commonly known as a "data subject access request" or “DSAR”). 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 5 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.
If you have any questions about this policy or about the use of your personal information or you 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.
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.
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