PRIVACY POLICY

In Communication Limited is committed to protecting and respecting your privacy. This privacy statement covers all use of services provided by In Communication Limited (hereto referred to as Incomm, we or us), these services include web sites and conferencing services accessed over the internet or by telephone

Scope

This Policy is intended to inform you of the reasons we collect personal data, the categories of personal data collected and the steps we take to protect the Personal Data that you choose to provide us with. We recommend that you carefully review this Policy. This Policy applies to our websites, to all the services offered by Incomm through our websites (Incomm services) and to all personal data directly or indirectly collected or otherwise receive from you, whether manually or digitally processed (Personal data). A customer (as defined below) may invite you to use this Site and / or the Incomm Services in order to participate in conferencing services initiated by them. This Policy does not apply to information our customers collect or receive from you and we cannot guarantee or enforce the privacy policies of our customers.

Why do we collect personal data?

Our legal basis for collecting personal data of conferencing participants is Legitimate Interest as a data processor to fulfil our obligations to our customers and to comply with contractual agreements. This information is provided to our customers to document who attended their conference call as our customers may have a regulatory / legal responsibility to accurately record attendance (for example MiFID II). This Policy does not apply to information our customers collect or receive from you and we cannot guarantee or enforce the privacy policies of our customers.

We are data controllers for the personal information pertaining to our customers which again falls under legitimate interest necessary for us to deliver our services to them and meet contractual agreements between us and the customer organisation.

Who do we collect personal data from?

We collect personal data from our customers in the form of contact information necessary to deliver services to them. We also collect personal data on conferencing participants to pass on to the call organiser so that they can have an accurate record of who attended their conference call.

What personal data do we process?

For customers we will typically record the following personal data in order to communicate with and deliver services to our customers:

  • Name
  • Company / Division
  • Company address
  • Business email address
  • Contact telephone numbers
  • Job Title

For conferencing participants joining a conference call we will typically record some of the following personal data on behalf of the call organiser either by an operator asking for the information or prior to the event using our event registration website:

Most Common:

  • Name
  • Company Name
  • The city location you are dialling in from

Less Frequently:

  • Job title
  • Staff number
  • Email address
  • Telephone number

How do we process your personal data?

For customers we will use your data in the following ways:

  • To improve our services and to ensure that our services are carried out in the most effective manner for you.
  • To provide you with information and updates on 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, your parent organisation and us.
  • To notify you about changes to our service.

We may also use your data to provide you with information about our services which may be of interest to you and we may contact you about these from time to time by email, post or telephone.

For Conferencing participants, the personal data you provide to gain access to a conference call is passed on to our customer (the call organiser who provided you with the dial in details). If instructed to do so by our customer, we may use your phone number to dial out to you in order to join you to a conference call. We will not use your personal data in any other way and we will not use the data to contact you in any way.

Where is personal data stored?

For customers, all personal data is stored within secure Microsoft data centres. Applications utilised to record, and access personal data include Microsoft Dynamics 365 Online and Microsoft Exchange for email correspondence. Data is encrypted at rest, in transit and in use and access to it is controlled by procedural controls (RBAC) and technical controls (strong authentication).

For conferencing participants, the data is stored on the website database of our event registration website for pre-registered participants and in the CDR data on our audio bridge for all participants. Records are protected as above.

All data centres mentioned above are physically located in the European Union.

How long do you retain personal data?

Our default retention period for customer data is 12 months from the date of last contact. We will contact the customer to confirm if they intend to continue to use our services or they wish for their record to be deleted. If we are unable to contact the customer, the record is deleted.

For participant data, this is set for automatic deletion after 6 months.

Disclosure

We may disclose Personal Information to third parties with whom we have contractual relationships in order to assist us in services when necessary for the provision of such services such as invoicing and transmission of e-mail communications. If Incomm discloses Personal Information to third parties acting as our agents, such third parties will be required to comply with our Privacy Policy. We may also disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary: (a) to the extent required by law; (b) to the extent required to respond to judicial process or a good faith belief that such action is necessary under law or to comply with legal process served on us; (c) to protect the security and integrity of the our websites and of Incomm Services; (d) to protect our rights and property and the rights and property of others; (e) to take precautions against liability; (f) to respond to claims that submitted information violates the rights or interests of third parties; (g) to correct technical problems and malfunctions in how our websites operate or processes visitors’ information; (h) in connection with a merger, consolidation or sale of all or substantially all of the shares or assets of one or more of our businesses; (i) to provide to our customers pursuant to your request in furtherance of ensuring that you do not receive further communications from our customers or from us; or (j) pursuant to our customers’ specific direction in connection with a service we are providing on behalf of our customers.

Use of third party cookies

Cookies for web analytics

We use third party services to gather data regarding the usage of our sites on our behalf using cookies, log file data and code which is embedded on our website. We use this type of information to help improve the service we provide to UK and non-UK visitors.

Google analytics

Google analytics is a web analytics service provider provided by Google Inc. Google analytics sets a cookie in order to evaluate a visitor’s use of our website.

Google stores the information collection by the cookie on their servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using our website, you consent to the processing of data about you by Google in the manner and the purposes set out above.

For more information on the cookie set by Google analytics, including information on how to opt out please go to www.google.com/intl/en/privacypolicy.html

Cookie Categories

The type of cookie used on this Site can each be put into 1 of 4 categories, based on the International Chamber of Commerce guide to cookie categories.

A. Strictly Necessary Cookies: These cookies are essential, as they enable you to move around a website and use its features, such as accessing secure areas. Without these cookies, services you’ve asked for (such as access to secure areas) cannot be provided. These cookies don’t gather information about you that could be used for marketing or remembering where you’ve been on the internet. These cannot be restricted or blocked.

B. Performance Cookies: These cookies collect information about how you use a website, for example which pages you go to most often and if you get any error messages from certain pages. These cookies don’t gather information that identifies you. All information these cookies collect is anonymous and is only used to improve how a website works. These cookies are not used to target you with online advertising. Without these cookies we cannot learn how our website is performing and make the necessary improvements that could enhance your browsing experience. These can be restricted or blocked.

C. Functionality Profile Cookies: These cookies allow a website to remember choices you make (such as your user name, language or the region you are in) and tailor the website to provide enhanced features and content for you. For instance, they remember your log-in details and allow you to watch videos. They also ensure the onsite marketing and experience is relevant to you. These cookies can also be used to remember changes you’ve made to text size, font and other parts of pages that you can customise. The information these cookies collect may be anonymous and they cannot track your browsing activity on other websites. Without these cookies, a website cannot remember choices you’ve previously made or personalise your browsing experience. These can be restricted or blocked.

D. Targeting Cookies: These cookies gather information about your browsing habits. They remember that you’ve visited a website and share this information with other organisations such as advertisers. They do this in order to provide you with ads that are more relevant to you and your interests. Although these cookies can track your visits to other websites, they don’t usually know who you are. Without these cookies, online advertisements you encounter will be less relevant to you and your interests. These can be restricted or blocked.

Cookies we use

This is a list of the main cookies we use and what each is used for:

Cookie name:_utma
Expires: 2 years
Category: Performance

Description: Used by Google Analytics. Each unique browser that visits a page on the site is provided with a unique ID via the __utma cookie. In this way, subsequent visits to the website via the same browser are recorded as belonging to the same (unique) visitor. Thus, if a person interacted with the website using different browsers, the Analytics reports would track this activity under two unique visitors. Similarly if the same browser were used by two different visitors, but with a separate computer account for each, the activity would be recorded under two unique visitor IDs. On the other hand, if the browser happens to be used by two different people sharing the same computer account, one unique visitor ID is recorded, even though two unique individuals accessed the site.

Cookie name: _utmb &_utmc
Expires: 30 min
Category: Performance

Description: Google Analytics uses these two cookies to establish a session. If either of these two cookies is absent, further activity by the user initiates the start of a new session.

Cookie name: _utmz
Expires: 6 months
Category: Functionality

Description: When visitors reach the site via a search engine result, a direct link, or an ad that links to the page, Google Analytics stores the type of referral information in a cookie. The parameters in the cookie value string are parsed and sent in the GIF Request (in the utmc variable). The expiration date for the cookie is set as 6 months into the future. This cookie gets updated with each subsequent page view to the site; thus it is used to determine visitor navigation within the site.

Cookie name:_ga
Expires: 2 years
Category: Performance

Description: This helps us count how many people visit www.incommglobal.com by tracking if you’ve visited before.

Cookie name: _gat
Expires: 10 minutes
Category: Performance

Description: Used to manage the rate at which page view requests are made.

Cookie name:_gid
Expires: 24 hours
Category: Performance

Description: Used to distinguish users.

Cookie name: PHP Session ID
Expires: End of session
Category: Functionality

Description: This cookie is a unique identifier for a session. It identifies a user’s session e.g. secure area log ins, email subscriptions.

Changes to our privacy policy

This policy was last updated on the 30/04/2018. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:

Andrew Clark
Chief Operating Officer / Data Protection Officer
In Communication Ltd
Compass House, 1-3 The Avenue, Southampton SO171XG
Email: andrew.clark@incommglobal.com