Privacy Policy

7. Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us (including if you subscribe to our ‘regular insights’).

8. Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

9. Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

10. Cookies

We use Cookies on Our Websites in order to optimise functionality.

You may block cookies by adjusting setting on your browser. Please note that if you restrict all cookies you may not be able to access all or parts of Our Websites. Unless you have configured your browser to refuse cookies, our system will issue cookies as soon you visit Our Websites.

When you first visit any of Our Websites a pop-up header will be generated alerting you to our cookie policy. It will re-appear in the event that you change your cookie settings from time to time.

A copy of our cookie policy, including details of how to opt-out, can be found here Cookie Policy. (hyperlink)

11. Change of purpose

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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

12. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the Purposes for which we will use your personal data table above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

If you have supplied your email address via Our Websites, we may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with us, our products, and our services.

We primarily use our ‘regular insights’ to communicate this type of information, so we expect to keep this type of email to a minimum.

If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. We take all measures reasonably necessary to protect against the unauthorised access, use, alteration, or destruction of your personal data.

13. International transfers

We conduct international transfers to for example the United States in accordance with an International Data Transfer Agreement.

14. Data retention

14.1 How long will we use your personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

We normally hold and process your data for a maximum of seven (7) years from the date when you last interacted with our services. If you have never interacted with our services, we will normally hold and process your data for forty eight months from the date when we first contact you about our services. In this context “interact” means following a link which we send you, or authenticating yourself on Our Websites. We will delete your data earlier where you request us to do so as provided for below.

In any event we will stop the processing of your data where you ask us to do so by contacting us by email at [email protected]; by post to Data Protection Co-ordinator, Inbox Insight Limited, 1 Exchange Square, Jewry Street, Winchester, Hampshire, SO23 8FJ; or by telephone on +44 (0)1962 831200. The only circumstances in which we will not do so are where we have a legal obligation or a legitimate interest to continue processing your data.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see (your legal rights) below for further information.

In some circumstances we will anonymise your personal 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.

15. How we deal with your legal rights

15.1 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 could refuse to comply with your request in these circumstances.

15.2 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.

15.3 Time limit to respond

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

16 Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of the contract for our services to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

17. THIRD PARTIES

17.1 Internal Third Parties

The members of our Group are our parent company Inbox Insight Group Limited (registered in England under number 10499998 whose address is Inbox Insight Limited, 1 Exchange Square, Jewry Street, Winchester, Hampshire, SO23 8FJ); and its subsidiaries, (registered in England under number 7179598 whose address is Inbox Insight Limited, 1 Exchange Square, Jewry Street, Winchester, Hampshire, SO23 8FJ); and Inbox Insight Inc (registered in Delaware under number 6243428) whose Address of Incorporation is at 2711 Centerville Road, Suite 400, Wilmington, New Castle, Delaware 19808, United States of America and whose Registered Address is at One Boston Place, Suite 2600, Boston, MA 02108, United States of America. We allow and you consent to any company in our group to process your personal information. Where we do so we confirm that those recipient companies will abide by the provisions of this Policy and accordingly this Policy also applies to each of those companies. as joint controllers or processors.

17.2 External Third Parties

Service providers acting as processors who provide IT and system administration services.

Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors in the United Kingdom who require reporting of processing activities in certain circumstances.

We may pass your details to our partners, or future partners, based on your access to the content on any of our services. This may include information about your interests derived from your activity on Our Websites. We may disclose information in the form of market research, aggregating it into reports or dashboards, which show trends in content consumption across our services. It may include a description of your activity on Our Websites and engagement with advertising, editorial and partner content. We may also provide our partners with your contact information and details of your interests for the purpose of further marketing, and they may use this information to contact you via email, telephone, mail, digital marketing or other means of communication. Our partners are subject to change so please check back regularly for updates.

We may share the details of our current and prospective clients with Reachdesk Ltd, for the purpose of sending you promotional gifts.

If you wish to opt out of this process please contact us by email at [email protected];
or by post to: Data Protection Co-ordinator, Inbox Insight Ltd, 1 Exchange Square, Jewry Street, Winchester, Hampshire, SO23 8FJ;
or by telephone on +44 (0)1962 831200.

Please contact our partners directly if you would like to opt out of their communications, but wish to continue to receive marketing communications from us, or making use of our services.

We use Citrix Systems Inc, HubSpot Inc, Salesforce.com Inc, Sales Blueprint Ltd, Unbounce Marketing Solutions Inc, Yesware Inc., and ZenLeads Inc., to assist us in managing your data. While some of these companies are not located in the United States, they are allowed to process your data in accordance with the GDPR via our International Data Transfer Agreement, in order to maintain the legitimacy of data transfer.

We may disclose your personal information to the extent that we are under a duty to disclose or share your personal data in order to:

• Comply with any legal obligation.
• Enforce or apply our terms of use and other agreements with you.
• Protect the rights, property, or safety of Inbox Insight, our customers, or others.
• This includes exchanging information with other companies and organisations for the purposes of fraud protection.

18. California Consumer Privacy Act (CCPA)

Under the California Consumer Privacy Act, California Civil Code Section 1798.100, if you are a resident of California you may contact us with regard to the following rights in relation to your personal data:

• Right of Access and Disclosure: You have a right to request access to the personal data we may hold on you for the past twelve (12) months. You may submit up to two (2) requests per year of access to your personal data.
• Right to Deletion: You have the right to ask us to delete personal data we may hold on you. There may be exceptions to the right to deletion for specific legal reasons which, if applicable, we will set out for you in response to your request.
• Right to Opt-Out of Sale of Personal Data: You have the right to opt-out of sale of personal data we may hold on you. You can exercise this right at any time.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your California Consumer Privacy Act rights.

If you wish to make any of these requests, please contact [email protected]. We will deal with requests for access to your personal data, or deletion requests, within forty-five (45) days for California-specific requests.

To help us respond as you expect, please specify that you are making a request under the California Consumer Privacy Act (CCPA). We may need to request specific information from you to help us confirm your identity.

19. Data Privacy Framework (DPF) Program

Inbox Insight complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Inbox Insight has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union, and the United Kingdom, in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

With respect to Personal Information received or transferred pursuant to the EU-U.S. Data Privacy Framework (EU-U.S. DPF), and the UK Extension to the EU-U.S. DPF, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We are potentially liable in cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-U.S. Data Privacy Framework (EU-U.S. DPF), and the UK Extension to the EU-U.S. DPF.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Inbox Insight commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, should first contact Inbox Insight via: [email protected].

Inbox Insight has further committed to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), and the UK Information Commissioner’s Office (ICO), with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, and the UK Extension to the EU-U.S. DPF. EU and UK individuals may invoke binding arbitration when other dispute resolution procedures have been exhausted.

20. EU Authorised Representative

Our representative in EEA under article 27 GDPR is Elena Riazanova, with their registered address at: Calle de Cullera 11, 3C, Madrid, Spain.

21. Your Legal Rights

You have the right to:

21.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

21.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

21.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

21.4 Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

21.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

21.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

These rights apply regardless of whether data is stored electronically, on paper or on other materials.

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