Welcome to the Inbox Insight website privacy policy (Policy).
Inbox Insight respects your privacy and is committed to protecting your personal data. This Policy aims to give you information on how we collect and process your personal data through your use of any of our websites detailed below (Our Websites), including any personal data you may provide when you subscribe to our regular insights service or purchase a product or service (and as set out in clause 4.1 below), regardless of where you visit Our Websites from, and tells you about your privacy rights and how the law protects you.
We gather and process data in accordance with the prevailing data protection legislation, including the General Data Protection Regulation (GDPR) 2016 and the Data Protection Act 2018.
This Policy applies to the following Inbox Insight companies:
(Collectively “we”, “us” or "our").
Our Websites are:
This Policy, together with our Bookings Terms and Conditions (a copy of which can be found here: www.inboxinsight.com/bookings-terms-and-conditions/), set out the basis on which we will process personal data we collect about you, or that you provide to us. It is important that you read this 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 Policy supplements other notices and privacy policies of ours and is not intended to override them.
Please also use the Glossary at clause 16 to understand the meaning of some of the terms used in this Policy.
We are the controller and responsible for your personal data.
We have 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.
If you have any questions about this Policy or our privacy practices, please contact our data privacy manager in the following ways:
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.
We keep our Policy under regular review. This version was last updated on 6th August 2023.
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.
Our Websites 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 Websites, we encourage you to read the privacy policy of every website you visit.
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 and process the following data about you:
Information that you provide:
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We do not collect any Special Categories of Personal Data about you (this includes 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). Nor do we collect any information about criminal convictions and offences.
We have implemented appropriate security measures to protect information from:
Our security systems include authenticated access to internal databases. We also encrypt and anonymise data wherever it is appropriate to do so. We regularly take back-ups of our data. We regularly review overall Web security and audit procedures.
In conforming with data protection laws, we endeavour to implement appropriate procedures to protect your personal data and to prevent any unauthorised access or misuse of it. Our servers, on which your personal data is kept, are located in the United Kingdom.
Please be aware that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data when transmitted via the internet to our site: any such transmission is at your own risk.
Where we need to collect personal data by law, or under the terms of the contract for our services 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 products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
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:
As you interact with Our Websites, we will automatically collect Technical Data about your language preference, equipment, browsing actions and patterns, referring site, time of each visitor request, and how many views a particular page or post received. We collect this personal data by using cookies, server logs and other similar technologies.
We will receive personal data about you from various third parties and public sources.
We will receive Technical Data from the following parties:
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 rely on legitimate interests as a legal basis for processing your personal data and we do not obtain consent prior to sending direct marketing communications, but we do obtain your consent prior to transferring data to a third party (who may then send their own marketing communications).
You have the right to withdraw consent to marketing at any time by contacting us.
In the performance of our services, we obtain information about individuals from third party sources such as data licensors.
This may mean that we hold data about individuals even though they have not knowingly interacted with us. To comply with our legal obligations, we rely on legitimate interests as a legal basis for processing such personal data and we do not obtain consent prior to sending direct marketing communications, but we do obtain consent prior to transferring data to a third party (who may then send their own marketing communications).
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 |
|---|---|---|
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To register you as a new client |
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Performance of a contract with you |
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To manage our relationship with you which will include:
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To enable you to complete a survey |
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To administer and protect our business and Our Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
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To deliver content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
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Necessary for our legitimate interests (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy |
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To use data analytics to improve Our Websites, products/services, marketing, client relationships and experiences |
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Necessary for our legitimate interests (to define types of clients for our products and services, to keep Our Websites updated and relevant, to develop our business and to inform our marketing strategy |
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To make suggestions and recommendations to you about products or services that may be of interest to you |
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Necessary for our legitimate interests (to develop our products/services and grow our business) |
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If you subscribe to receiving our ‘regular insights’ - to ask you to provide a contact name and work email address |
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Necessary for our legitimate interests (to develop our products/services and grow our business |
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.
You will receive marketing communications from us (including if you subscribe to our ‘regular insights’).
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us 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, warranty registration, product/service experience or other transactions.
We use Cookies on Our Websites in order to optimise functionality.
You may block cookies by adjusting setting on your browser. Please note that if you restrict all cookies you may not be able to access all or parts of Our Websites. Unless you have configured your browser to refuse cookies, our system will issue cookies as soon you visit Our Websites.
When you first visit any of Our Websites a pop-up header will be generated alerting you to our cookie policy. It will re-appear in the event that you change your cookie settings from time to time.
A copy of our cookie policy, including details of how to opt-out, can be found here Cookie Policy.
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.
We may share your personal data with the parties set out below for the purposes set out in the Purposes for which we will use your personal data table above.
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 Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
If you have supplied your email address via Our Websites, we may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with us, our products, and our services.
We primarily use our ‘regular insights’ to communicate this type of information, so we expect to keep this type of email to a minimum.
If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. We take all measures reasonably necessary to protect against the unauthorised access, use, alteration, or destruction of your personal data.
We conduct international transfers to for example the United States in accordance with an International Data Transfer Agreement.
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.
We normally hold and process your data for a maximum of seven (7) years from the date when you last interacted with our services. If you have never interacted with our services, we will normally hold and process your data for forty eight months from the date when we first contact you about our services. In this context “interact” means following a link which we send you, or authenticating yourself on Our Websites. We will delete your data earlier where you request us to do so as provided for below.
In any event we will stop the processing of your data where you ask us to do so by contacting us by email at privacy@inboxinsight.com; by post to Data Protection Co-ordinator, Inbox Insight Limited, 1 Exchange Square, Jewry Street, Winchester, Hampshire, SO23 8FJ; or by telephone on +44 (0) 1962 831200. The only circumstances in which we will not do so are where we have a legal obligation or a legitimate interest to continue processing your data.
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.
In some circumstances you can ask us to delete your data: see (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.
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.
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 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.
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 the contract for our services 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.
The members of our Group are our parent company Inbox Insight Group Limited (registered in England under number 10499998 whose address is Inbox Insight Limited, 1 Exchange Square, Jewry Street, Winchester, Hampshire, SO23 8FJ); and its subsidiaries, (registered in England under number 7179598 whose address is Inbox Insight Limited, 1 Exchange Square, Jewry Street, Winchester, Hampshire, SO23 8FJ); and Inbox Insight Inc (registered in Delaware under number 6243428) whose Address of Incorporation is at 2711 Centerville Road, Suite 400, Wilmington, New Castle, Delaware 19808, United States of America and whose Registered Address is at One Boston Place, Suite 2600, Boston, MA 02108, United States of America. We allow and you consent to any company in our group to process your personal information. Where we do so we confirm that those recipient companies will abide by the provisions of this Policy and accordingly this Policy also applies to each of those companies. as joint controllers or processors.
Service providers acting as processors who provide IT and system administration services.
Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors in the United Kingdom who require reporting of processing activities in certain circumstances.
We may pass your details to our partners, or future partners, based on your access to the content on any of our services. This may include information about your interests derived from your activity on Our Websites. We may disclose information in the form of market research, aggregating it into reports or dashboards, which show trends in content consumption across our services. It may include a description of your activity on Our Websites and engagement with advertising, editorial and partner content. We may also provide our partners with your contact information and details of your interests for the purpose of further marketing, and they may use this information to contact you via email, telephone, mail, digital marketing or other means of communication. Our partners are subject to change so please check back regularly for updates.
We may share the details of our current and prospective clients with Reachdesk Ltd, for the purpose of sending you promotional gifts.
If you wish to opt out of this process please contact us by email privacy@inboxinsight.com; or by post to:
Data Protection Co-ordinator,or by telephone on +44(0)1962 831200.
Please contact our partners directly if you would like to opt out of their communications, but wish to continue to receive marketing communications from us, or making use of our services.
We use Citrix Systems Inc, HubSpot Inc, Salesforce.com Inc, Sales Blueprint Ltd, Unbounce Marketing Solutions Inc, Yesware Inc., and ZenLeads Inc., to assist us in managing your data. While some of these companies are not located in the United States, they are allowed to process your data in accordance with the GDPR via our International Data Transfer Agreement, in order to maintain the legitimacy of data transfer.
We may disclose your personal information to the extent that we are under a duty to disclose or share your personal data in order to:
Under the California Consumer Privacy Act, California Civil Code Section 1798.100, if you are a resident of California you may contact us with regard to the following rights in relation to your personal data:
If you wish to make any of these requests, please contact privacy@inboxinsight.com. We will deal with requests for access to your personal data, or deletion requests, within forty-five (45) days for California-specific requests.
To help us respond as you expect, please specify that you are making a request under the California Consumer Privacy Act (CCPA). We may need to request specific information from you to help us confirm your identity.
Inbox Insight complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Inbox Insight has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union, and the United Kingdom, in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit: https://www.dataprivacyframework.gov/.
With respect to Personal Information received or transferred pursuant to the EU-U.S. Data Privacy Framework (EU-U.S. DPF), and the UK Extension to the EU-U.S. DPF, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We are potentially liable in cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-U.S. Data Privacy Framework (EU-U.S. DPF), and the UK Extension to the EU-U.S. DPF.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Inbox Insight commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, should first contact Inbox Insight via: privacy@inboxinsight.com.
Inbox Insight has further committed to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), and the UK Information Commissioner’s Office (ICO), with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, and the UK Extension to the EU-U.S. DPF. EU and UK individuals may invoke binding arbitration when other dispute resolution procedures have been exhausted.Our representative in EEA under article 27 GDPR is Elena Riazanova, with their registered address at: Calle de Cullera 11, 3C, Madrid, Spain.
You have the right to:
21.1 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.
21.2 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.
21.3 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.
21.4 Object to processing of your personal data where we are relying on a legitimate interest 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.
21.5 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:
21.6 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.
These rights apply regardless of whether data is stored electronically, on paper or on other materials.
If you wish to exercise any of the rights set out above, please contact us.
Issue: 20240801.1