InterComm International Limited (InterComm) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tells you about your privacy rights and how the law protects you.
This privacy policy aims to give you information on how InterComm collects and processes your personal data though your interactions with us.
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. This privacy policy supplements the other policies and is not intended to override them.
InterComm is the controller and responsible for your personal data (also referred to as 'we', 'us' or 'our' in this privacy policy).
InterComm International Limited
The Green Hill
1 Cambridge Road
Linton
Cambridge
CB21 4NN
United Kingdom
Alternatively, you have the right to make a complaint to the Information Commissioner's Office, the UK supervisory authority for data protection issues (www.ico.org.uk).
This version was last updated on 23 May 2018.
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 time working with us.
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 various kinds of personal data about you, which we have grouped together follows.
Special Categories of personal data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any Special Categories of personal data about you.
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 services we have agreed with you. These circumstances may necessitate us cancelling the contract, services provision agreement or statement of work that we have with you.
We use different methods to collect data from and about you. These include the following methods.
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
Generally, we do not rely on consent as a legal basis for processing your personal data.
You have the right to ask us to delete your personal data at any time by contacting us: privacy@intercomm.co.uk
We have set out below a description of all the ways we may use your personal data, and which of the legal frameworks we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose |
Type of data |
Lawful basis for processing |
To register you as a new client or supplier |
|
Performance of a contract with you |
To process and deliver our service to you including:
|
Performance of a contract with you.
Necessary for our legitimate interests. |
|
To manage our relationship with you including:
|
|
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our services) |
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
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 use data analytics to improve our website |
|
Necessary for our legitimate interests (to keep our website updated) |
To make suggestions and recommendations to you about services that may be of interest to you |
|
Necessary for our legitimate interests (to develop our products/services and grow our business) |
You can ask us to stop sending you marketing messages at any time by contacting us at any time: privacy@intercomm.co.uk
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service agreement or contract that we have entered into with you
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 and permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
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.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered, disclosed, used or accessed in an unauthorised way. 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.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, insurance valuation or reporting requirements.
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 requirements.
Details of retention periods for different aspects of your personal data are available upon request from us.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of your rights, please contact us: privacy@intercomm.co.uk
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 may refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within 28 days. If your request is particularly complex or you have made a number of requests it may take us longer than 28 days to respond. In this case, we will notify you and keep you updated.
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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.
You have the following legal rights.
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: