Privacy Policy

PRIVACY AND COOKIES POLICY

 

Welcome to the InvestIN’s privacy policy.

 

InvestIN Education Ltd respects your privacy and is committed to protecting your personal data. This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and tells you about your privacy rights and how the law protects you.

 

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.investin.org (our Site) you acknowledge and are accepting and consenting to the practices described in this policy.

 

1. IMPORTANT INFORMATION AND WHO WE ARE

 

InvestIN, is the trading name for InvestIN Education Ltd, a company registered in England and Wales. Our company registration number is 08179629 and our registered office is at 85 Great Portland Street, First Floor, London, W1W 7LT.

 

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

 

Controller 

 

InvestIN Education Ltd (“We, Us or Our”) is the controller and responsible for your personal data.

 

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

 

Contact Details 

 

If you have any questions about this policy or our privacy practices, please contact our data privacy manager in the following ways:

 

By post to: InvestIN, 85 Great Portland Street, First Floor, London, W1W 7LT

 

By email to: info@investin.org 

 

By phone: +44 (0) 203 488 5089

 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

Changes To this Policy and Your Duty to Inform Us of Changes

 

We keep our privacy policy under regular review. This version was last updated on 29 July 2020. 

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

Third Party Links

 

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

2. THE DATA WE COLLECT ABOUT YOU

 

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).

 

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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes home and or billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• 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.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our Site, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

 

If you register for an InvestIN programme we collect some Special Categories of Personal Data about you (this includes details about your race or ethnicity,) for the purposes of enabling us to provide you with information about targeted opportunities (such as work experience) and to assist us with meeting any requirements you may have when attending the programme (for example, if you have any dietary requirements).

 

Minors

 

We are mindful that some of our courses are attended by minors who, by law, cannot consent to the processing of their personal data if they are under the age of 13.

 

Any booking made for any child under the age of 18 must be submitted by either a parent who holds parental responsibility for the child, or by a school/institution which they attend who has the necessary authority to provide the information on the child's behalf.

 

By submitting a booking you are specifically providing consent to our processing of the child’s personal data.

 

Photography and Videoing at Events. 

 

From time to time we will take photos and videos of students during their time at an event. The purpose of this is to assist us with training and refreshing the programme content, as well as for use in promotional material. In addition, some recorded programme content will be made available to other students who could not attend on the day for personal reasons.

Our lawful basis for processing this information will be either consent or legitimate interests, depending on the processing activity. 

 

If You Fail to Provide Personal Data

 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product, service or event you have with us but we will notify you if this is the case at the time.

 

3. HOW IS YOUR PERSONAL DATA COLLECTED?

 

We use different methods to collect data from and about you including through:

 

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• request our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• participate in discussion boards or other social media functions on our Site;
• report a problem with our Site;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.

 

Information From Other Sources

 

This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this Site. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

 

4. HOW WE USE YOUR PERSONAL DATA

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation. Please refer to the Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.
• Where we have your consent to do so, for example to send you information about targeted opportunities that may be of interest to you (or your child).  We will also get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw your consent at any time by contacting us.

 

 

Purposes For Which We Will Use Your Personal Data

 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

   

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Identity Contact	Performance of a contract with you
To process a registration request and bookings, manage payments, fees and charges and collect and recover money owed to us	Identity Contact Financial Transaction Profile Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests to take and make payments.
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how users use our Site)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how users use our Site)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To make suggestions and recommendations to you about offers or services that may be of interest to you	Identity Contact Technical Usage Profile Marketing and Communications	Necessary for our legitimate interests (to define types of customers for our products and our services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
To provide you with information about targeted opportunities which may be of interest to you, for example in relation to relevant work experience	First name Surname Date of birth Email address School/College Country of residence Careers you’re interested in (list of 20 they can tick as many as they like) Gender Ethnicity Religion Disability	Consent (and explicit consent for special category data, for example your ethnicity)

 

Marketing

 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

 

• Promotion 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 (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
• Third Party Marketing:We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
• Opting Out: You can ask us or third parties 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, a product/service experience or other transactions.
• Cookies:You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy below.
• 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.

 

5. DISCLOSURES OF YOUR PERSONAL DATA

 

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

 

• Internal and External Third Parties as set out in the Glossary.
• Specific third parties, such as the university, college or other venue for which you have made a booking.
• 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 privacy policy.
• Our affiliate partner Graduway, who we use to facilitate the InvestIN Connect App, for the purpose of providing you with information through the InvestIN Connect App. 

 

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.

 

6. INTERNATIONAL TRANSFERS

 

The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

 

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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries:

 

https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_lt

 

 

• 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 Europe and the US. For further details, see European Commission: EU-US Privacy Shield:

 

https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-data-transfers_en

 

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

 

7. 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.

 

8. DATA RETENTION

 

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.

 

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.

 

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

 

In some circumstances you can ask us to delete your data: see 9 - 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.

 

9. YOUR LEGAL RIGHTS

 

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

 

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

 

Please refer to the Glossary below for more detailed information on your rights.

 

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 could 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 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.

 

10. 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 a contract 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.

 

Third Parties 

 

• Internal Third Parties:Other companies in the InvestIN Group and who provide IT and system administration services and undertake leadership reporting.

 

• External Third Parties:May be based inside and outside of the EEA and include:
• Venues where events are to take place and the relevant persons (staff/presenters) at those venues that are booked using the website, business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers. We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience; and
• Analytics and search engine providers that assist us in the improvement and optimisation of our site;
• Service providers acting as processors who provide IT and system administration services. This includes third parties who assist with facilitating the InvestIN Connect App, for example Graduway.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

 

Your Legal Rights

 

You have the right to:

 

• 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.

 

• 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.

 

• 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.

 

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) 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.

 

• 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.

 

• 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.

 

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

11. COOKIES POLICY

 

Our Site uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

 

We use the following cookies:

 

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

 

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

 

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.