ITRS GROUP PRIVACY NOTICE
Last updated: November 24, 2023
ITRS GROUP LIMITED (“WE”/ “OUR”/ “US”) ARE COMMITTED TO PROTECTING AND RESPECTING YOUR PRIVACY.
The data controller of your personal information is ITRS Group Limited of 15 Bonhill Street, London, EC2A 4DN, United Kingdom.
Information we may collect from you
We may collect and process the following data about you:
Information that you provide voluntarily
We may ask you to provide personal information voluntarily, for example:
- Prior to certain calls with our staff (customer-facing roles only) you will be asked whether you object to your call being video recorded and transcribed via third-party tools, such as Gong.
- Information that you provide by filling in forms on our websites, including www.itrsgroup.com, resources.itrsgroup.com, support.itrsgroup.com, and any subdomains of those websites. This includes information provided at the time of registering to use the client login area on our websites, subscribing to our service, and posting material or requesting further services.
- If you contact us, we may keep a record of that correspondence.
- To complete surveys that we use for product development and research purposes.
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the applicable time.
Information processed automatically
- Details of transactions you carry out when using our websites and of the fulfilment of your orders.
- When you visit our websites, we may collect certain information automatically from your device.
Types of personal information processed
Personal information that we may collect about you as part of the processing above includes:
- Video recording including transcript (via third party recording tools referred to above);
- IP address;
- Device type;
- Unique device identification numbers;
- Broad geographic location (e.g. country or city-level location);
- We may also collect information about how your device has interacted with our websites, including the pages accessed and links clicked; and
- Work contact information (e.g. full name, address, title, employer, employment history, contact details).
Collecting this information enables us to better understand the visitors who come to our websites, where they come from, and what content on our websites is of interest to them. We use this information for our analytics, employee training and performance monitoring, and to improve the quality and relevance of our websites.
Some of this information may be collected using cookies and similar tracking technology, as explained below.
Information that we obtain from third-party sources
From time to time, we may receive personal information about you from third party sources. We may collect personal information from third party tools including Google Analytics, and LinkedIn and we combine the information we receive from these third parties with the information obtained directly from you.
Cookies and other tracking technology
Reasons for processing your personal information
We may process your personal information for the following reasons:
- To analyse visitor traffic, improve the customer experience, and maintain the accuracy of the records we hold about you;
- To ensure that content from our websites is presented in the most effective manner for you and for your computer;
- To provide you with information, products or services that you request from us or which we feel may interest you;
- To carry out our obligations arising from any contracts entered into between you and us;
- To allow you to participate in interactive features of our services; and
- To notify you about changes to our products and services.
Our websites may, from time to time, contain links to and from the websites of our partner networks. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will collect personal information from you only: (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you.
Legitimate interests may include: (i) operating our platform and communicating with you as necessary to provide our services to you (such as responding to your queries), (ii) platform improvements, (iii) marketing, or (iv) for the purposes of detecting or preventing illegal activities.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.
Disclosure of your information
In addition to the use(s) set out above, we may further process your personal information in the following circumstances:
- To our group companies. A list of our current group companies can be provided upon request;
- To our sub-processors or sub-contractors who provide data processing services to us (for example, to support the delivery of our services, provide functionality on, or help to enhance the security of our site);
- To any competent law enforcement body, regulatory, government agency, court, or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish, or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- To an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business;
- To distributors and/or resellers who are authorized partners of ours for the purposes of delivering our product; and
- To any other person with your consent to the disclosure.
Where we store your personal information
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers (for example in places such as Spain, United States of America, Canada, Hong Kong, Singapore and the Philippines). Such staff may be engaged in, among other things, the fulfillment of an order and the provision of support services.
However, in the event of a transfer of your personal information outside of the EEA, we will take all appropriate steps and put in place appropriate technical and organizational measures to safeguard your personal information in accordance with this Privacy Notice and in accordance with all applicable law.
We use appropriate technical and organisational measures to protect your personal information and consider privacy-by-design in all elements of handling your personal information. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.
Specific measures we may include encrypting your personal information in-transit, encrypting at-rest, and implementing multi-factor authentication access control. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
We will only retain your personal information for so long as we continue to have a legal basis to do so for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements.
We will either delete or anonymise your personal information in accordance with our data retention policy, subject to personal information that may be stored in backup systems, which cannot be readily accessed for deletion purposes. In the event your personal information is kept beyond our standard retention period(s), then it will be securely stored and deleted (or anonymised) as soon as reasonably practicable.
Our websites and products are not targeted to individuals under the age of 18, and we do not intentionally process any personal information of children under 18.
You may have the following data protection rights:
- To access, correct, update or request deletion of your personal information;
- To object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information;
- To opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you;
- If we have collected and process your personal information on the legal basis of consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal; and
- You have the right to complain to a data protection authority about our processing of your personal information. The applicable data protection authority in the United Kingdom is the Information Commissioners Office (the UK ICO).
To exercise any of your rights set out above, please contact us using the details provided below.
Changes to our Privacy Notice
We reserve the right to make changes to this Privacy Notice from time to time, and any such changes will be published on our website. The revision date of the Privacy Notice will be set out at the bottom of the Privacy Notice.
If you have any questions or concerns about our use of your personal information, please contact us using the following details:
Address: c/o ITRS Group, 15 Bonhill Street, London, EC2A 4DN