Privacy policy

What information do we collect?

Personal information you disclose to us

In short: we collect personal information that you provide us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and services, when you participate in activities on the services, or otherwise when you contact us.

We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In short: Some information, such as your Internet Protocol (IP) address) and/or browser and device characteristics is collected automatically when you visit our services.

We automatically collect certain information when you visit, use, or navigate the services.

This information not reveal your specific identity such as your name or contact information, but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our services, and other technical infromation.

This information is primarily needed to maintain the security and operation of our services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie notice: https:www.innovate-trust.org.uk/cookie-policy.

The information we collect includes:

• Log and usage data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our services and which we record in log files.
  Depending on how you interact with  us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), decide event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).
• Device data. We collect decide data such as information about you computer, phone, tablet, or other device you use to access the services.
  Depending on the device used, this decide data may include information such as your IP address (or proxy server), decide and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location data. We collect location data such as information about your devices location, which can either be precise or imprecise.
  How much information we collect depends on the type and settings of the GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address).
  You can opt out of allowing us to collect this information by refusing access to the information or by disabling your location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the service.
  
  

How do we process your information?

In short: we process your information to provide, improve, and administer our services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our services, including:

• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our services.
• To protect our services. We may process your information as part of our efforts to keep our services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect and individual’s vital interest, such as to prevent harm.

What legal bases do we rely on to process your information?

In short: we only process your personal information when we believe it is necessary and we have a valid legal reason (such as legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

The General Data PRotection Regulation (GSPR) and UK GDPR requires us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (consent) to use your personal information for a specific purpose. You can withdraw consent at any time. 
• Legitimate interest. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of these purposes describe in order to:
  • analyse how our services are used so we can improve them to engage and retain users
  • support our marketing activities
  • diagnose problems and/or prevent fraudulent activities
  • understand how our users use our products and services so we can improve user experience
• Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
  
  

When are with whom do we share your personal information?

In short: we may share information in specific situations described in this section and/or with the following categories of third parties.

Vendor, consultants, and other third-party service providers.

We may share your data with third-party vendors, service providers, contractors, or agents (‘third parties‘) who perform services for us or on our behalf and require access to such information to do that work.

We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means they cannot do anything with your personal information unless we have instructed them to do it.

They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

Categories of third parties

The categories of third parties we may share personal information with are as follows:

• Data analytics services
• Website hosting service providers

We also may need to share your personal information with the following situations:

• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  
  

Do we use cookies and other tracking technology?

In short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our services.

Some online tracking technologies help us maintain the security of our services, preventing crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to you interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our services or on other websites.

Specific information about how we use such technologies and how you can refuse certain cookies is set our in our cookie notice: https://www.innovate-trust.org.uk/cookie-policy.

Google analytics

We may share your information with Google Analytics to track and analyse the use of the services. The Google Analytics Advertising Features that we may use include: Google Analytics Demographics and Interests Reporting and Google Display Network Impressions Reporting.

To opt out of being tracked by Google Analytics across the services, visit: https://tools.google.com/dlpage/gaoptout.

You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps.

Other opt our means include https://optout.networkadvertising.org/ and https://thenai.org/opt-out/mobile-opt-out/. 

For more information on the privacy practices of Google, please visit the Google Privacy and Terms page.

How long do we keep your information?

In short: we keep your information for as long as necessary to fulfil the purposes outline in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if that is not possible (for example, because your personal information has been sorted in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How do we keep your information safe?

In short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100 percent secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our services is at your own risk. You should only access the services with a secure environment.

Do we collect information from minors?

In short: we do not knowingly collect data from, or market to, children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the services. 

If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us using our online form or the address found in ‘how can you contact us about this notice?’ section.

What are your privacy rights?

In short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to, and control over, your personal information. 

You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These include the right:

• to request access and obtain a copy of your personal information
• to request rectification or erasure
• to restrict the processing of your personal information
• if applicable, to data portability
• not to be subjected to automated decision-making.

In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using our online form or the address found in ‘how can you contact us about this notice?’ section.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or Uk and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using our online form or the address found in ‘how can you contact us about this notice?’ section.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Cookies and similar technologies

Most web browsers are set to accept cookies by default.

If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our services. For further information, please see our cookie notice:  https://www.innovate-trust.org.uk/cookie-policy

If you have any questions or comments about your privacy rights, you may contact us using our online form or the address found in ‘how can you contact us about this notice?’ section.

Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a do-not-track (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. 

If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this policy notice.

Do we make updates to this notice?

In short: yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘revised’ date at the top of this privacy notice.

If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes, or by directly sending you a notification. 

We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

How can you contact us about this notice?

If you have questions or comments about his notice, you may email us by using our online form or contact us by post at:

Innovate Trust
433 Cowbridge Road East
Caerdydd
CF5 1JH
Cymru

How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information.

You may also have the right to withdraw your consent to our processing of your personal information.

These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please contact us for a data subject access request form.