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Understand what personal information we collect and how it will be handled.

At IMPOWER we respect your right to privacy online and understand that you want to keep control of your personal information. That’s why we are committed to protecting any information you share with us.

We will never sell, distribute or intentionally make your personal information public and have implemented appropriate technical and organisational security measures to protect the data you share with us from loss and preserve its security and confidentiality. All your interactions with our website are protected by strong 256-bit encryption and we aim to collect the minimum of personal information needed to provide an effective service.

We believe in being transparent about what data we are collecting and how it will be handled. The information below sets out our privacy policy in detail. In each case we’ll explain why a particular piece of data is being processed and how long it will be retained. We are also committed to providing relevant information and control at the point of collection so that you can make informed decisions about what personal data you choose to share with us.

Our Legal Bases for Processing

We collect and process information about you only where we have legal bases for doing so. This legal bases will depend on the individual services you use and how you use them. Additional information is provided below but in general terms we will only collect and use your information where:

  • It is necessary for us to provide you with a service, including for support or to protect the safety and security of the services itself.
  • It satisfies a legitimate interest which is not overridden by your data protection interests. Such as for research and development.
  • You have given us consent to do so for a specific purpose.
  • We need to process your data to comply with a legal obligation.

In cases where you have consented to our use of your personal information for a specific purpose you have the right to change your mind at any time. Where we are using your information because we have a legitimate interest to do so, you have the right to object to that use, but in some cases this may mean your are no longer able to access our services.

Third Party Data Processors

Like most businesses we rely on a number of third-party providers to support our day-to-day operations, for example in areas such as online file storage and email delivery. We may also hire third parties to operate, maintain or improve our website and other digital services. Some of these service providers will by necessity have access to or be directly involved in processing or storing a subset of the personal information you share with us.

All our third-party data processors have been carefully chosen as service suppliers who also practice responsible data handling. We believe that each has in place appropriate protections to ensure the security of the data we store or process with them and have clear policies for how they treat that data. But if in doubt you should review their individual Privacy Policies.

The Pixel Parlour (Digital services development & support):
https://www.pixelparlour.co.uk/about/privacy-and-cookies/

Amazon Web Services (File storage):
https://aws.amazon.com/compliance/data-privacy-faq/

Google (Website analytics):
https://support.google.com/analytics/answer/6004245?hl=en

HeartInternet (Hosting & email services):
https://www.heartinternet.uk/terms/heart-internet-privacy-statement

Hubspot (Website analytics):
https://legal.hubspot.com/privacy-policy

MailChimp (Email marketing):
https://mailchimp.com/legal/privacy/

Microsoft (Email services):
https://privacy.microsoft.com/en-GB/privacystatement

Before using or sharing your information with third parties in ways not described here or previously authorised by you, we will provide you with notice and an opportunity to control the further use or disclosure of your personal information.

Transfers outside of the European Economic Area
Under certain circumstances we will transfer your information outside of the European Economic Area. We will only do this with your informed consent, when it is necessary to perform a contract we have with you or where the receiving organisation has adequate safeguards in place – for example certification under the EU-US Privacy Shield framework.

General Browsing
Our website is hosted in the UK in a data centre managed by Heart Internet. When you visit our website or access one of the files stored on our web server information about this request will be automatically stored in our log files to provide usage statistics, enable security features and aid technical troubleshooting. This is on the legal basis of legitimate commercial interests. In these cases your IP address at the time acts as a unique identifier and is stored along with information about your operating system, browser version and the pages/files you access. These logs are retained on the server for up to 30 days, after which they are automatically deleted. Heart Internet will also record a similar set of data for the purposes of data management and security. This data is retained by them for up to 3 months.

Like most businesses we use Google Analytics to help understand how our website is being discovered and interacted with and we use this information to help improve the experience for our visitors and make decisions about future development. Google Analytics presents us with aggregate information about the geographic location, device types and operating systems used by our website visitors, but not in a way that personally identifies you. Additionally Google will record your computer’s IP address and set a number of temporary cookies in your browser to help distinguish you as an individual visitor as you move around our site. In the interests of limiting the amount of data Google collects via our site we are using Google’s standard Analytics implementation and have not enabled any additional advertising features, such as remarketing tags which would tie your usage of our site in with your broader browsing habits. Any user-level data that is associated with Analytics’ cookies are retained for up to 26 months from your last activity on our site, after which it is automatically deleted from Analytics’ servers.

Our website and emails contain a number of links to third party sites. It is important to be aware that these external sites are governed by their own privacy policies and we do not accept any responsibility or liability for these policies. The inclusion of a link to an external source should not be understood to be an endorsement of that website, its owners or their products/services. Always check the individual privacy policies of these external sites before you submit any personal data through them.

Cookies
Cookies are temporary files stored in your web browser by a website to help track usage and enable services that rely on a persistent identity. You can control which cookies you accept and remove them at any time by adjusting your browser settings, but it is important to be aware that some cookies are essential and our website may not function as expected without them.

Essential cookies

These cookies are strictly necessary to provide you with services available through our websites and to use some of its features. But you can still block or delete them by changing your browser preferences.

  • None currently set

Non-essential cookies

These cookies are used to enhance the performance and functionality of our websites. They are non-essential but without them certain functionality may become unavailable.

  • YSC (YouTube) – used to support playback of embedded YouTube videos. Expires at the end of your session.
  • VISITOR_INFO1_LIVE (YouTube) – used to support playback of embedded YouTube videos. Expires after 8 months.
  • PREF (YouTube) – used to support playback of embedded YouTube videos. Expires after 8 months.

Analytics and customisation cookies

These cookies collect information to help us understand how our website is being used or customise it in order to enhance your experience.

  • _ga (Google Analytics) – used to distinguish between users. Expires after 2 years.
  • _gat (Google Analytics) – used to distinguish between users. Expires after 24 hours.
  • _gid (Google Analytics) – used to throttle the request rate. Expires after 1 minute.
  • loc, mus, ssc, uid, uvc (AddThis) – set by the service we use to provide social sharing to record usage stats, including the geographic location of sharers. Expire after 1 month.
  • __hstc (Hubspot) – records a timestamp of a user’s first visit, last visit, and total number of sessions. Expires after 13 months.
  • hubspotutk (Hubspot) – used to keep track of a visitor’s identity and passed to HubSpot on form submission to deduplicate contacts. Expires after 13 months.
  • __hssc (Hubspot) – keeps track of sessions and used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. Expires after 30 minutes.
  • __hssrc (Hubspot) – whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. Expires at end of session.

Advertising cookies

These cookies are used to make advertising messages more relevant to you and your interests.

  • None currently set

Email Marketing
We use MailChimp for our email marketing. So when you subscribe to our newsletter or download one of our reports the email address and name you submit will be held securely by them and the information also made accessible to us. MailChimp’s servers are based in the United States, so your information may be transferred to, stored, or processed in the US. MailChimp participates in and has certified its compliance with the EU- U.S. Privacy Shield Framework, which certifies that is has adequate safeguards in place. As a respected email marketing provider MailChimp won’t share your information with any unauthorised third parties or contact you directly at any time – you can read their full privacy policy here: https://mailchimp.com/legal/privacy/

We use a double opt-in process where a confirmation email will be sent to the email address supplied with a link to click. Only after clicking that link will you be opted-in to receive our emails. At this point MailChimp will also collect your IP address, which along with a timestamp helps provide our evidence of consent should we need to provide this to the regulator.

By default we will retain your data in MailChimp for as long as you choose to stay subscribed or such time as we consider your account to be in-active (ie. you are no longer opening or engaging with our emails).

You can update your details or opt-out of our emails at any time using the ‘Unsubscribe’ or ‘Email Preferences’ links found at the bottom of every email we send via MailChimp. If you unsubscribe MailChimp will retain your email address for the purposes of a suppression list to ensure that no further marketing messages can be sent unless you actively choose to opt-in again.

In addition to the information you supply at sign-up MailChimp will also capture data about your interactions with our emails and website, such as which links you click within an email which pages you go on to visit on our website. It does this using a combination of tracking pixels and cookies. You can learn more about those in the Cookies section of this privacy policy. We use this information to help improve our product and provide more personalised messaging.

We may also combine the information you provide us at sign-up with data from other sources, such as our website, to help us improve the relevance of the emails we send you. For example if you are also a member we will record that information in your MailChimp subscriber profile to ensure that the content of our emails reflects that.

Contacting us by Email

When you send us an email, either to one of the addresses displayed on our website or an an individual member of staff, we will collect your email address and any other information you provide within your email.

Microsoft are our email service provider so any emails you send us will be stored on their servers. Therefore your email and any associated personal data may be transferred outside of the European Economic Area to servers located in the USA. Microsoft’s certification under the EU-US Privacy Shield Framework commits it to maintaining appropriate safeguards for international data transfers. You can learn more here: https://privacy.microsoft.com/en-GB/privacystatement

The information you provide will only be processed in relation to the purpose of your correspondence with us. We have no fixed retention period for email correspondence, but we are committed to only storing your data for no longer than is necessary to serve our legitimate interests of record keeping or to perform a contract we have entered into with you.

Children Under 16
Our website and services are not for use by children under 16 years and we will not knowingly collect or use the personal data of children. If you are under the age of 16 please do not provide any personal data even if prompted to do so.

Personal Data Breaches
A breach is considered any loss, alteration, unauthorised disclosure of, or access to, personal data. We are committed to disclosing any personal data breaches that might adversely affect your rights and freedoms without undue delay so that you can take appropriate action. Any notifiable breaches will also be reported to the UK’s Information Commissioner’s Office within 72 hrs. This includes breaches affecting the third party services identified in this privacy policy, where personal data is being held on our behalf.

Questions & Access Requests
The General Data Protection Regulation (2018) gives you the right to know what person data we hold, to have it updated if it is inaccurate or removed entirely if you no longer consent to our use of it. We will endeavour to respond to any such requests within one month confirming receipt and outlining what follow-up actions will be taken and when.

We also welcome questions about our Privacy Policy and these or any access requests should be directed to our Data Protection Officer: enquiries@impower.co.uk / IMPOWER, Attn. Data Protection Officer, 112-114 Middlesex Street, London E1 7HY.

Policy Changes
Any updates we may make to our Privacy Policy in the future will be published on this page and significant changes noted below.

13 March 2019 – Cookies section updated to reflect Hubspot analytics being added to the site.

9 May 2018 – Expanded Privacy Policy published in preparation for the new General Data Protection Regulation

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