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Privacy Policy

IMRG Limited (“IMRG”) is a membership organisation for online retailers providing resources and services for its members and other parties in the retail industry (together the “Services”). For more information please see About us.

This privacy policy sets out how the IMRG collects and uses personal information about individuals. Please read this privacy policy carefully to understand how IMRG will use your personal information.

Although our members are businesses, not individuals, we do collect and use personal information relating to individuals as part of our activities. This is generally in order to manage our membership and to carry out our wider work providing resources and information to online retailers in the UK. We also collect personal information about individuals who sign up to our events, surveys, information or subscription services, or to receive our briefings. We also collect data on other individuals we work with.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager by email at membership@imrg.org or by post at IMRG Limited, 16 Neal’s Yard, London, WC2H 9DP.

We are a data controller in respect of the personal data we collect and for the registered on the Information Commissioner's Office Register registration number ZA084392.

This privacy policy explains:

1.    How we collect your data

2.    Information we may collect about you

3.    Use of your information

4.    Contacting you

5.    Our legal basis for collecting, holding and using your information

6.    Sharing your information

7.    Cookies

8.    International transfers

9.    Security and storage of your information

10.  Data security

11.  Data retention

12.  Your rights

 

HOW WE COLLECT YOUR DATA

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Information you give to us. You may give us information about you by filling in an online form, contacting us by phone or e-mail or in person. This includes information you provide if you complete a membership form on behalf of a business, if you register to attend one of our events or sign up to our newsletter or other information and subscription services. You may also give us your information if you complete an application form or otherwise apply for a job here, either directly, or via a third party.

Information we collect about you. The IMRG also uses cookies to automatically collect information about individuals visiting our website. Please see the section “Cookies” below and our Cookie Policy.

Information we receive from other sources. We work closely with other organisations, such as business partners, sub-contractors, analytics providers, search information providers, and we may receive information about you from them.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

 

INFORMATION WE MAY COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

•  Identity Data includes first name, last name, username or similar identifier, title and email address.

•  Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

•  Usage Data includes information about how you use our website and Services.

•  Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

 

USE OF YOUR INFORMATION

We need to obtain, store and use information about you for legitimate business purposes - namely so that you can enjoy and benefit from our Services.  We may use information we hold about you in the following ways:

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

CONTACTING YOU

An important part of our work is communicating with our membership, so we use personal information to keep in touch with individuals within our member organisations, as well as partners and other individuals.

We will use the contact information you have given us to send you important information. This may be by post, email, text message or telephone.

We may also use the information we hold about you, in order to provide you with information about our other products or services we feel may interest you.

Because we operate primarily with businesses rather than individuals, we do not generally seek your consent to send you marketing communications. We believe that such communications are both in our legitimate interests, to raise awareness of our work and promote our services, and in your interests to receive information about the retail index, webinars and events that benefit you and your business. 

However, you can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time.

 

OUR LEGAL BASIS FOR COLLECTING, HOLDING AND USING YOUR INFORMATION

Data protection law sets the lawful legal bases (or ‘conditions’) which allow us to collect, hold and use your personal information. For IMRG, these are:

Data protection law recognises certain "special categories" of personal information, which include information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information for uniquely identifying a person, information concerning health, and information concerning a person's sex life or sexual orientation. These special categories are considered particularly sensitive and so we will only collect and use this information where you have given us your explicit consent or where we consider it necessary to do so.  For example, you may choose to tell us about your health condition before attending one of our events.  We will only use this information for the particular event or campaign and not for any other purposes.

 

SHARING YOUR INFORMATION

We may share your information with selected third parties including:

We may also share your personal information to third parties if we are under a duty to disclose or share your personal data, in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety of our customers, or others.

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

 

COOKIES

Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page. Cookies serve many functions, for example, they can help us to remember your username and preferences, analyse how well our website is performing and allow us to send you content that we believe will be most relevant to you.

We use the following types of cookie:

Some cookies are essential for the operation of our website and allow us to identify IMRG members, so we can ensure they can access the member-only pages. If a member opts to disable these cookies, the member will not be able to access all of the content that a membership entitles them to. By accepting the use of login functionality, you must agree to the setting of specific cookies which allow these areas to function

We utilise other cookies to analyse how visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customising our offering and quickly identifying and fixing any issues that arise. From tracking the most popular pages to finding out why some pages are receiving error messages, we use these cookies to highlight articles or site services that we think will be of interest to you based on your usage of the website.

Functionality cookies allow us to remember your preferences. Cookies save you the trouble of typing in your username every time you access the site, and recall your preferences, such as which sections of the website you want to see when you log in.

IMRG also use third party cookies such as Google Analytics to help us monitor our website traffic. These third party cookies may help us with market research, revenue tracking, improving site functionality and monitoring compliance with our terms and conditions and copyright policy. For example, surveys or comparisons may be added by third parties as added functionality. We will endeavour to ensure full disclosure of any cookies from third party websites.

When you accessed our site, you should have seen an overlay which explained that by continuing to access our site, you are consenting to our use of cookies. You can choose to disable cookies. Please remember that if you do choose to disable cookies, you may find that certain sections of our website do not work properly.

For more information about the cookies we use, please see our Cookie Policy.

 

INTERNATIONAL TRANSFERS  

Some of our Third Parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

•  We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

•  Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

•  Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

•  Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

DATA SECURITY  

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

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

DATA RETENTION - HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

By law we have to keep basic information about our customers for six years after they cease being customers. In some circumstances you can ask us to delete your data and please see below for more information.

In some circumstances we may anonymise your personal data and company data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

If you wish to exercise any of the rights set out above, please Contact us.

 

NO FEE USUALLY REQUIRED  

You will not have to pay a fee to access your personal data (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 may refuse to comply with your request in these circumstances.

 

WHAT WE MAY NEED FROM YOU  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.

 

TIME LIMIT TO RESPOND  

We try to respond to all legitimate requests within one month. Occasionally it may 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.