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.
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:
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):
Amazon Web Services (File storage):
Google (Website analytics):
HeartInternet (Hosting & email services):
Hubspot (Website analytics):
MailChimp (Email marketing):
Microsoft (Email services):
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.
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 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.
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.
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.
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.
These cookies are used to make advertising messages more relevant to you and your interests.
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.
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
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.
13 March 2019 – Cookies section updated to reflect Hubspot analytics being added to the site.