Privacy & Cookies Policy

Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    In this policy, “we”, “us” and “our” refer to Insite Group Holdings Ltd. For more information about us, see Section 7.

2.      How we use your personal data

2.1    In this Section 2 we have set out: (a)    the general categories of personal data that we may process; (b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; (c)    the purposes for which we may process personal data; and (d)    the legal bases of the processing.

2.2    We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent.

2.3    We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of providing our services, ensuring the security of our services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our business.

2.4    We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent

2.5    We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you, your employer or agent. The source of the customer relationship data is you, your employer or agent. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing our legitimate interests, namely the proper management of our customer relationships

2.6    We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

2.7    We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with users.

2.8    We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.9    We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.10  In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.11  Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3.      Providing your personal data to others

3.1    We may disclose your correspondence data to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy

3.2    We may disclose your correspondence data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3    We may disclose your correspondence data to our suppliers or subcontractors insofar as reasonably necessary for performing our contract.

3.4    In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.      Retaining and deleting personal data

4.1    This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

4.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

4.3    We will retain your personal data as follows: (a)    Account, Customer Relationship and Correspondence data will be retained for a minimum period of 3 years following completion of contract, and for a maximum period of 6 years following completion of contact. (b)    Transaction Data will be kept for the period required by legislation.

4.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria: (a)    the period of retention of Publication Date will be determined based on the life of the publication.

4.5    Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5.      Amendments

5.1    We may update this policy from time to time by publishing a new version on our website.

5.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

6.      Your rights

6.1    In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

6.2    Your principal rights under data protection law are: (a)    the right to access; (b)    the right to rectification; (c)    the right to erasure; (d)    the right to restrict processing; (e)    the right to object to processing; (f)    the right to data portability; (g)    the right to complain to a supervisory authority; and (h)    the right to withdraw consent.

6.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

6.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

6.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

6.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

6.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

6.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

6.9    You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

6.10  To the extent that the legal basis for our processing of your personal data is: (a)    consent; or (b)    that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

6.11  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

6.12  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

6.13  You may exercise any of your rights in relation to your personal data [by written notice to us.

7.      Our details

7.1    This website is owned and operated by Insite Group Holdings Ltd

7.2    We are registered in Scotland under registration number SC547211, and our registered office is at 64 Coltness Street, Glasgow G33 4JD 7.3    Our principal place of business is at 64 Coltness Street, Glasgow G33 4JD

7.4    You can contact us by post, to the postal address given above;

8.      Data protection officer

8.1     Our data protection officer’s contact details are: Jane McCready, 64 Coltness Street, Glasgow. G33 4JD Cookies Policy A cookie is a small data file that certain websites write to a hard drive when a user visits that website. The only personal information a cookie can contain is information a user personally supplies. A cookie cannot read data from a user’s hard disk or read cookie files created by other websites. Cookies, however, enhance our website’s performance in a number of ways including providing a secure way for-to identify verification during a visit to a website and personalising the user’s experience with the website while making it more convenient for the user. Insite Group Limited may therefore use cookie technology to track or record information about visitors to this website. These cookies are “session specific” and are not used to record personal information or to associate personal information with the use of this website. Privacy and security are not compromised if and when the user accepts a cookie from this website. Users can refuse cookies by turning them off on their web browsers (see under “Tools” and then “Internet Options”) and users do not need to have cookies turned on to successfully use this website.