- When we say ‘we’, ‘us’ or ‘InspireX’ it’s because that’s who we are and we own and run the Sites.
The type of personal information we collect
- We collect certain personal information about visitors and users of our Sites.
- The most common types of information we collect include things like: user-names, member names, email addresses, IP addresses, other contact details, survey responses, user interface files, device configuration settings, payment billing address, transactional details, tax information, support queries, forum comments, content you direct us to make available on our Sites (such as item descriptions) and web analytics data. We will also collect personal information from job applications (such as, your CV, the application form itself, cover letter and interview notes).
How we collect personal information
- We collect personal information directly when you provide it to us, automatically as you navigate through the Sites, or through other people when you use services associated with the Sites.
- We collect your personal information when you provide it to us when you complete membership registration and buy or provide items or services on our Sites, subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, or send us a communication.
Personal information we collect about you from others
- Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular:
- financial and/or transaction details from payment providers located in the US, UK, and Australia in order to process a transaction;
- third party service providers (like Google, Facebook) who are located in the US or UK, which may provide information about you when you link, connect, or login to your account with the third party provider and they send us information such as your registration and profile from that service. The information varies and is controlled by that service provider or as authorized by you via your privacy settings at that service provider; and other third party sources/ and or partners from US, whereby when we are required to validate your Harman account ID for purchasing, we receive information such as the organization name, address and location associated with the account id.
How we use personal information
- We will use your personal information:
- operating the Sites;
- providing you with services described on the Sites;
- verifying your identity when you sign in to any of our Sites;
- Verifying your identity when using licenses products with our Sites
- responding to support tickets, and helping facilitate the resolution of any disputes;
- updating you with operational news and information about our Sites and services e.g. to notify you about changes to our Sites, website disruptions or security updates;
- carrying out technical analysis to determine how to improve the Sites and services we provide;
- monitoring activity on the Sites, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Sites;
- managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Sites or asking for your feedback or whether you want to participate in a survey;
- managing our legal and operational affairs (including, managing risks relating to content and fraud matters);
- training InspireX staff about how to best serve our user community;improving our products and services; and
- providing general administrative and performance functions and activities.
- providing you with marketing information about products and services which we feel may interest you; and
- To fulfil a contract, or take steps linked to a contract: in particular, in facilitating and processing transactions that take place on the Sites, like which item you purchase from our online store.
- Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:
- Where you give us consent:
- For purposes which are required by law.
- For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.
How we identify devices using our services
- To use the TPControl product with our Sites a license is applied to the device running the application. To ensure the license is verified and validated to the correct user and to prevent fraudulent activity, we use a device identifier and license identifier generated on our Sites and store the identifier locally on the device.
- The identifier of the device and license is sent to the Sites in which an acknowledgment is received to validate the device has permission to use the service.
- The identifier allows us to associate the user who purchased the license that is being used on the device but does not allow us to identify the user of the device.
When we disclose your personal information
- We will disclose personal information to the following recipients:
- Our internal sales and development team which are located in UK, Australia, USA and Ukraine;
- companies that are part of the Inspire Group UK, which are located in Australia and the UK;
- Harman International which are based in the US;
- subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: website hosting providers which are located in US and UK; technical and customer support services which are located in Australia, US and Ukraine; recruitment agencies which are located in Australia; marketing and analytics services which are located in Australia; security and fraud prevention services which are located in the US; subscription management services which are located in the US; payment processing services which are located in the US and UK; identification verification services located in the US; and operational tooling services which are located in the US. Noting that our subcontractors and services providers may also transfer and access such information from other countries in which they have operations.
- our professional advisers (lawyers, accountants, financial advisers etc.) which are located in the UK and Australia;
- regulators and government authorities in connection with our compliance procedures and obligations;
- a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase;
- a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;
- a third party, in order to enforce or defend our rights, or to address financial or reputational risks;
- a rights holder in relation to an allegation of intellectual property infringement or any other infringement; and
- other recipients where we are authorised or required by law to do so.
Where we transfer and/or store your personal information
- We are based in the UK with an administration team in Australia and our data servers are based in the US, so your data will be processed in the UK, Australia and the US. Some of the recipients we have described in section 10 above, and to whom we disclose your personal information, are based outside of these regions, in places like Canada, Ireland and the US. We do this on the basis of your consent to this policy. In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.
How you can access your personal information
- You can access some of the personal information that we collect about you by logging in to your account. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data. You can also close the account you have with us for any of our Sites by contacting our support team (firstname.lastname@example.org) and making a request. To make an access or correction request, contact our privacy champion using the contact details at the end of this policy or make a request to email@example.com.
Marketing Choices regarding your personal information
- Where we have your consent to do so (e.g. if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.
- You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our Sites may not work properly in your case.
Cookies and web analytics
When you visit our Sites, there’s certain information that’s recorded which is generally anonymous information and does not reveal your identity. If you’re logged into your account some of this information could be associated with your account. We’re talking about the following kinds of details:
- your IP address or proxy server IP address’;
- the domain name you requested;
- the name of your internet service provider is sometimes captured depending on the configuration of your ISP connection;
- the date and time of your visit to the website;
- the length of your session;
- the pages which you have accessed;
- the number of times you access our site within any month;
- the file URL you look at and information relating to it;
- the website which referred you to our Sites; and
- the operating system which your computer uses.
When you use our products that require interaction with our Sites like TPControl, there’s certain information that’s recorded which is associated to the license recorded on the device which can be associated with a user account. This does not give the identity of the person using the device, only the identity of who purchased the license in use. The following kinds of details are recorded:
- your IP address or proxy server IP address’;
- the domain name you requested;
- the token ID for the license on the device;
- The device ID we associated to the device on installation; and
- error reports that have been created internally when using the application;
- We do not use third party advertising companies to serve ads.
Information about children
- Our Sites are not suitable for children under the age of 16 years, so if you are under 16 we ask that you do not use our Sites or give us your personal information (if you are a young tech wiz, please direct your nearest responsible adult to use the Sites for you!). If you are from 16 to 18 years, you can browse the Sites but you’ll need the supervision of a parent or guardian to become a registered user. It’s the responsibility of parents or guardians to monitor their children’s use of our Sites.
Information you make public or give to others
- You are responsible for keeping your password and user details confidential. We will not ask you for your password.
How long we keep your personal information
When we need to update this policy
- We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.
- When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.
How you can contact us
- If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact our privacy champion in writing at “The Town House” 114-116 Fore Street, Hertford, Hertfordshire SG14 1AJ, United Kingdom or firstname.lastname@example.org
If you’re a user or visitor in the European Economic Area these rights also apply to you:
- For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.
How you can access your personal information
- You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.
- These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.
- Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.
- If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
This is InspireX, effective date 25 May 2018