Processing personal data

Iforium handles personal information in compliance with applicable Data Protection Legislation.  We recognise the importance of the correct and lawful processing of personal data in maintaining confidence in our operations.  We fully endorse and adhere to the principles set out within the legislation.

Registration as a data controller

Iforium is a ‘Data Controller and Processor’ as recognised by the Isle of Man Data Protection Law 2018.  Iforium has notified the Information Commissioner’s Office in the Isle of Man that we control and process personal data to enable us to provide our services to our clients, to maintain our own accounts and records, and to support and manage our staff.  Our registration details, should you wish to verify them are:

Isle of Man: https://www.inforights.im – Registration Number: R000768

Once Iforium has your data, for example, when you provide your personal data to Iforium, through our website, Iforium is the data controller for that data.  You are still the owner of your data and are the data subject.

Processing information fairly and lawfully

Iforium processes information only where:

• we have a legitimate interest to do so, or
• a contract has been entered that allows us to, or
• is in the vital interests of the data subject (lifesaving), or
• you have given your explicit consent, or
• we have received a court order.

We will not process personal data unless one of the above conditions apply.

Information we collect

Iforium believes in the principle or transparency regarding what data we are collecting and why we are collecting it so that the relevant data subjects can make informed decisions about whether they want their data to be processed or not.

Iforium collects data to operate effectively and to enhance the services that we provide to our employees, suppliers, providers and operators.

Information we collect about you:

We may collect and process data about you:

• If you contract with Iforium we will keep the records applicable for the execution of the contract between us;
• If you contact us directly, we may keep a record of that correspondence;
• When you provide information to us by filling in forms on any of our websites;
• When you report a problem through any of our websites;
• By recording details of your visits to any of our websites including, but not limited to:
  • Google Analytics – We use online tracking systems that collect your IP address and the details of any organisation associated with it when you visit the Iforium website. It also records activity on this website, detailing any pages that have been visited, so that we can improve our marketing activities and improve the performance of our websites to enhance the level of service that you receive from Iforium.
  • Cookies – Details on the cookies that Iforium use can be found within the Cookies Policy page on our website.

We use this information:

• to ensure that content from our website is presented in the most effective manner for you and for your device;
• where we have your permission to do so, to send you messages to provide you with information about Iforium and the products or services that we offer, that you have requested, or which we feel may be of interest to you. More detail on our marketing activities can be found in the Marketing section;
• to carry out our obligations arising from any contracts entered between you or the organisation for whom you work and Iforium;
• to notify you about changes to our service.

All data processed by Iforium about you will be stored within our business systems and retained in accordance with the Retaining Information section of this policy.

Ensuring your personal information is safe and accurate

Iforium ensures that information held on our computer systems and in our paper filing systems is secure, to guard against unauthorised or unlawful processing or accidental loss, destruction of, or damage to personal data.

Iforium only collects and records personal information that is necessary to carry out its functions, nothing more. To the extent that it is reasonable and appropriate to do so, Iforium will check that the personal information being collected and recorded is accurate.

Data sharing

We do not pass your details to third parties unless we are instructed to do so by court order or you provide permission for us to do so.

Where we store your data

Iforium data and systems are physically located on servers in the UK and the Isle of Man.  At any given time, your data may be stored by these Data Processors within their data centres.  Although we use the services provided by these organisations they do not have access to your data.  The Isle of Man currently has an agreement with the EU in relation to its Data Protection Legislation, recognising that the Isle of Man has adequate (in terms of the directive) data protection legislation.

Retaining information

We will only retain your personal information if a business need exists.  It is not kept longer than is necessary for that purpose.  To this end, Iforium has in place and applies a formal retention policy for the information that it holds.  If you wish to see our retention policy please send a request to the Data Protection Officer, whose contact details are provided in the Invoking Your Rights section.

Marketing

Iforium will only contact individuals who have subscribed to Iforium newsletters, or requested direct communication for marketing purposes, and only in relation to Iforium products and/or services.

Should you wish to no longer receive marketing communications from Iforium:

• an unsubscribe facility is available within the marketing email which opens a webpage to allow you to request no further marketing contact from Iforium, or;
• you can reply to the individual who has contacted you requesting no further marketing contact, or;
• you can send a request to the Data Protection Officer, whose contact details are provided in the Invoking Your Rights section.

After any of these have occurred, Iforium will not directly contact you in this regard again unless you provide a subsequent request to start receiving it again.

Links to other websites

The Iforium website may, from time to time contain links to other websites.  Linking should not be taken as an endorsement of any kind.  We cannot guarantee that links will work all the time and we have no control over the availability or content of the linked pages.  We encourage you to read the privacy statements on the other websites you visit, prior to fully using them, as this (Iforium’s) privacy policy does not extend to those sites.

Your rights

As detailed within the applicable Data Protection Legislation, each Data Subject is afforded a number of rights.

In accordance with these rights Iforium will, upon request:

• Provide you with all the data Iforium hold about you, in a machine-readable format;
• Provide you with access to any or all the data that Iforium hold about you, and provide you with details about why we have the data;
• Rectify any information about you that is deemed incorrect;
• Unless we are required to continue doing so by legislation, stop, or where applicable, restrict the processing of data about you;
• Remove all records about you from our systems, providing that there is not a legal reason to retain it. If there is a legal reason we will inform you of it and provide you with details about how much longer we are required to retain your data for.

Invoking your rights

If you wish to invoke any of the rights afforded to you, then you must request this in writing, providing your contact details.  Once you have submitted a request, we may contact you to verify your identity. You should send your request to:

Data Protection Officer

Iforium Limited
Rose House
Floor 1
51-59 Circular Road
Douglas
Isle of Man
IM1 1AZ

Email: [email protected]

Complaints about how we process your personal information

In the first instance, an individual should contact Iforium. Complaints should be addressed to:

Data Protection Officer
Iforium Limited
Rose House
Floor 1
51-59 Circular Road
Douglas
Isle of Man
IM1 1AZ

Email: [email protected]

Should you feel that your complaint has not been dealt with in a satisfactory manner, you may escalate your complaint to:

The Chief Executive Officer

Iforium Limited
Rose House
Floor 1
51-59 Circular Road
Douglas
Isle of Man
IM1 1AZ

Email: [email protected]

Should you again feel that the response provided is not satisfactory, then you should forward your complaint to the Isle of Man Information Commissioner’s Office, whose contact details can be found at www.inforights.im/contact-us/.