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Privacy Policy

The Institute of Promotional Marketing Privacy Policy

Privacy Notice Last Updated 18 May 2018

We respect the privacy of every person who visits or registers with or submits personal information through our website at theipm.org.uk (the “Site”) and who uses the products and services that we offer, including from the Site, and we are committed to ensuring a safe online experience.

Purpose of this privacy notice

This Privacy Notice (“Privacy Notice”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Notice also sets out your rights in respect of our processing of your personal information. This Privacy Notice informs you of the nature of the personal information about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it. This Privacy Notice is intended to assist you in making informed decisions when using the Site, taking out membership and using and our products and services. Please take a moment to read and understand it. It should be read in conjunction with our terms.

This Privacy Notice only applies to the use of your personal information obtained by us; it does not apply to personal information collected during your communications with third parties.

About us

The Site and our products and services are made available by The Institute of Promotional Marketing Limited (“The IPM”).

The IPM is the data controller responsible for your personal information.

The IPM is a company limited by guarantee registered in England under registration number 00975635 with its registered office located at 21 Bedford Square, London, England, WC1B 3HH and its principal place of business at Holborn Hall, 193-197 High Holborn, London WC1V 7BD.

How to contact us

If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, please: Send us an email at: contact@theipm.org.uk

Call us on: +44 (0)20 3848 0444

Write to us at: The Institute of Promotional Marketing Limited, Holborn Hall, 193-197 High Holborn, London WC1V 7BD

Personal information we collect and how we use it

Our primary reasons for collecting personal information from you is to: (i) provide our products and services to you; (ii) verify your identity (where applicable); (iii) help us improve our Site and our products and services and develop and market new products and services; (iv) carry out requests made by you on the Site; (v) investigate or settle enquiries or disputes; (vi) comply with applicable law, court order, other judicial process and the requirements of regulators; (vii) enforce our agreements with you; (viii) protect the rights, property and safety of us or third parties, including our other members and users of the Site; (ix) provide support for the provision of our products and services; (x) carry out recruitment activities; (xi) carry out credit checking where relevant and (xii) use as otherwise required or permitted by law.

In particular, we use your personal information for the following purposes:

Fulfilment of our products and services. We collect and maintain personal information that you voluntarily submit to us during your use of the Site and when you purchase products from us or use our services.

Guest registration and log in: If you register with the Site as a guest, we will use your name, company name, position and email address to process your registration. Once you are registered, we will process your email address and password to identify you when you log into secure areas of our Site. We will use your account information so that we can administer your account with us.

Membership registration and log in: If you register as a member with us, we will use your name, contact details, payment details and any personal information in any references to process your membership application and registration. Once you are registered, we will process your email address and password to identify you when you log into secure members areas of our Site. We will use your account information so that we can administer your membership with us and contact you about your membership (including in relation to renewals).

Legal advice services: We collect your name and contact details (including telephone number and email address) and any other personal information you volunteer when you request our members’ legal advice service and we use such information to provide you with the advice you have requested.

Events: We use your name and contact details, your payment details (where applicable) and any other personal information you volunteer when you sign up to attend one of our events.

Courses: We use your name and contact details, your payment details (where applicable) and any other personal information you volunteer when you sign up to attend one of our courses

Service purchases: We use the contact and payment details you have provided so that we can fulfil the supply of products you have ordered from our Site and to process any returns and/or refunds. Any contractual terms relevant to the particular products you have ordered will also apply.

Promomarketing Newsletters: If you subscribe, we use the contact details you have provided to send you newsletters from our Promotional Marketing website. You may unsubscribe at any time from the newsletter.

Who do we share your personal information with for this purpose?

We will share your personal information with the following categories of third parties as necessary when supplying our products and services:

  • Credit card companies and other payment and vetting providers who assist us with the verification of card payments and the processing of refunds, as well as credit checking services;
  • Delivery and courier companies who assist us with delivering products ordered from us;
  • Law firms who assist us in providing legal advice in relation to the advice services we provide to our members;
  • Web hosting, optimisation and management companies who assist us with the hosting, operation, optimisation and maintenance of our Site, the administration of your account with us and the provision of access to secure areas and functionality on our Site;
  • Email service providers who assist us with sending out our news and marketing emails.

Please note this list is non-exhaustive and there may be circumstances where we need to share personal information with other third parties in order to provide the products and services as effectively as we can. Some of our third party providers are located in the USA and their use of your personal information is governed by the EU-U.S. Privacy Shield.

What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the products and services you have requested in an effective and efficient way.

General customer services and enquiries

Our Site features a “Contact us” form to allow you to submit enquiries about our Site and our products and services online. We also accept enquiries by email, telephone and post. When making an enquiry, the enquirer’s name and contact information (including email address, postal address and telephone number, as applicable) may be requested, together with details of other personal information that is relevant to the enquiry. This information is used to enable us to manage and respond to your enquiries and requests.

Who do we share your personal information with for this purpose?

We use a third party service provider to assist us with member service enquiries. What is our legal basis? It is in our legitimate interest to use your personal information in such a way to ensure that we provide a good standard of customer service to you.

Your feedback about our products and services

From time to time, we may invite you to provide feedback about our products and services in the form of online or postal surveys. We will collect your name and contact details (including email address, postal address and telephone number, as applicable) and any other personal information you choose to volunteer in your feedback. We use this information to help us improve the quality of service provided by our staff. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and service lines.

Who do we share your personal information with for this purpose? We may use third party service providers to assist us with processing member and visitor feedback. Some of our third party providers are located in the USA and their use of your personal information is governed by the EU-U.S. Privacy Shield.

What is our legal basis? It is in our legitimate interest to use the personal information provided by you in your feedback for the purposes described above.

User insight and analysis

At times, we may analyse your contact details with other personal information that we observe about you from your interactions with our Site, with our email and/or telephone communications to you and/or with our products and services. We may record information about our interactions with you on our customer relationship management system which enables us to provide member benefits more efficiently. Where you have given your consent (where lawfully required), we may also use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile device.

This includes the following:

  • an IP address to monitor Site traffic and volume;
  • a session ID to track usage statistics on our Site; and
  • information regarding your personal or professional interests, demographics, experiences with our products and contact preferences.

Our web pages and emails may contain cookies, web beacons and pixel tags (“Tags”). Tags allow us to track receipt of an email to you, count users who have visited a web page [or opened an email] and collect other types of aggregated information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to the source email and/or the relevant Tag.

In some of our email messages, we may use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications. Please see our Cookie Policy for further information. This information is used to create insights about our visitors’ browsing habits on our Site.

Where we have your consent to do so, we may also use your location data for insight and analysis purposes. By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our products and services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of features and functionalities our visitors and clients like to see. We also use this information to help us with the selection of future product and service lines and website design and to remember your preferences. We may also use this information for marketing purposes (see the “Marketing Activities” section below for further details).

Who do we share your personal information with for these purposes? We share your personal information with third party service providers to assist us with insight analytics. These providers are described in our Cookie Policy. Some of our third party providers may be located in the USA and their use of your personal information is governed by the EU-U.S. Privacy Shield.

What is our legal basis? Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide good quality products and services to you and our other visitors and clients. We will only use your location data for insight and analysis purposes where we have your consent to do so.

Marketing activities

We carry out the following marketing activities using your personal information:

Postal marketing. We may use your name and address to send you marketing communications by post. Such communications will include information about the products, services, events, offers and promotions we offer from time to time. Our postal marketing may include personalised and non-personalised postal marketing.

Personalised marketing is marketing which has been specifically tailored to you. For example, our personalised postal marketing will feature products, services, events, offers and/or promotions that we think are most likely to appeal to you.

Non-personalised marketing is marketing about our products, services, events, offers and/or promotions generally and is not tailored to any particular individual. Where we are sending you personalised postal marketing, we also use information that we observe and have recorded on our customer relationship management system about you from your interactions with our Site, with our email communications to you and/or with our products and services and to decide what sort of personalised marketing communications to send you. Please see the “User Insight and Analysis” section above for more details about the personal information collected and how it is collected.

Who do we share your personal information with for these purposes? We may share your personal information with third party postal providers who assist us in delivering our postal marketing campaigns to you, including Royal Mail or other couriers.

What is our legal basis? Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details. Where your personal information is not in an anonymous form, which will be the case with your postal address, it is in our legitimate interest to use your personal information for marketing purposes. We will only use your location data where we have your consent to do so.

Email marketing. We use your name and email address to send you marketing communications by email, where you have consented to receive such marketing communications or where we have another lawful right to do so. Such communications will include information about the products, services, events, offers and promotions we offer from time to time. Our email marketing may include personalised and non-personalised email marketing.

Personalised marketing is marketing which has been specifically tailored to you. For example, our personalised email marketing will feature our products, services, events, offers and/or promotions that we think are most likely to appeal to you.

Non-personalised marketing is marketing about our products, services, events, offers and/or promotions generally and is not tailored to any particular individual. If we are sending you personalised email marketing, we will also use information that we observe about you from your interactions with our Site, with our email communications to you and/or with our products and services in order to decide what sort of personalised marketing communications to send you. We also use information we have recorded on our customer relationship management system from our dealings with you. Please see the “User Insight and Analysis” section above for more details about the personal information collected and how it is collected.

Who do we share your personal information with for these purposes? We share your personal information with third party email marketing providers who assist us in delivering our email marketing campaigns to you. Some of our third party providers are located in the USA and their use of your personal information is governed by the EU-U.S. Privacy Shield.

What is our legal basis? Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes. We will only send you marketing communications by email where you have consented to receive such communications, or where we have another lawful right to do so. We will only use your location data where we have your consent to do so.

Prize draws, prize competitions and other promotions

From time to time, we may run prize draws, prize competitions and other promotions on our Site and/or on our social media accounts. For the purposes of administering such promotions, we may process your name, contact details (including email address, postal address and/or telephone number, as applicable), social media handle (if relevant) and any other personal information volunteered by you in your promotion entry.

Who do we share your personal information with for these purposes? We may share your personal information collected in connection with any prize draws, prize competitions and other promotions that we run with any third party providers that assist us with the administration of such promotions. Some of our third party providers are located in the USA and their use of your personal information is governed by the EU-U.S. Privacy Shield.

What is our legal basis? It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you (e.g. the terms and conditions applicable to the promotion) or it is in our legitimate interest to use your personal information to enable you to participate in any prize draws, prize competitions and other promotions.

Recruitment

We use your personal information for recruitment purposes, in particular, to assess your suitability for any position for which you may apply at The IPM, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third party recruitment agency on your behalf.

We may process any personal information about you that you volunteer when you apply for a job at The IPM. Such information may include your name and contact information (e.g. email address, postal address, telephone number), personal information concerning your education, qualifications and employment history and any other personal information which appears in your curriculum vitae or which is relevant to your potential recruitment. Who do we share your personal information with for these purposes? Where applicable, we will share your personal information with external recruiters.

What is our legal basis? Where we use your personal information in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions. We will not process any special (or sensitive) categories of personal information eg health or disability or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

Business administration and legal compliance

We use your personal information for the following business administration and legal compliance purposes: to comply with our legal obligations; to enforce our legal rights; to protect the rights of third parties; and in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets.

Who do we share your personal information with for these purposes? We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities. We may also share personal information with other entities within our group of companies for these purposes.

What is our legal basis? Where we use your personal information in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent. Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes, will be notified to you using your contact details.

How we obtain your consent

Where our use of your personal information requires your consent, you can provide such consent: at the time we collect your personal information following the instructions provided; or by informing us by email, post or telephone using the contact details set out in the “How to Contact Us” section above.

Our use of cookies and similar technologies

Our Site may use certain cookies, web beacons, pixel tags, log files and other technologies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information about how the website is used.

We use the following cookies on our website:

A number of Google analytics cookies are used to collect information about how visitors use our site. We use the information to compile reports which help us to improve our website.

A temporary session ID cookie is used to make the most efficient use of resources when you are browsing from page to page. The cookie is removed when you leave our website.

A visitor cookie is used to monitor how long a visitor is on our site before they take an action (for example fill in one of our forms to contact us) and also to provide statistics on whether this is a visitor’s first visit to our site. These cookies collect information in an anonymous form, we are not able to identify individual users from these cookies.

If you do not wish to allow this use of cookies, you may be able to change the settings on your browser to disable them. There is more information to help you on this link: www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Third party links and services

Our Site contains links to third party websites and services. When you use a link to go from our Site to another website or you request a service from a third party, this Privacy Notice no longer applies. Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control or endorse the privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy notices and practices.

This Privacy Notice applies solely to personal information collected by us through our Site, the supply of our products and services and/or in connection with our business operations and does not apply to these third party websites and third party service providers.

Transfers outside the EEA

Where necessary in order to deliver our services, we may transfer personal information to countries outside the EEA. When doing so, we will comply with our legal and regulatory obligations in relation to the personal information including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.

How long we keep your personal information

Regarding personal information we have processed in connection with the supply of our products and services to any member, we will retain personal information relevant to that supply of products or services for six years from the date of supply and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

Regarding any other personal information we have processed, we will retain relevant personal information for three years from the date of our last interaction with the relevant individual and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability. If any personal information is only useful for a short period (e.g. for a specific marketing campaign), we may delete it at the end of that period. If you have opted out of receiving marketing communications from us, we will need to retain certain personal information indefinitely so we do not send you marketing communications again.

Confidentiality and security of your personal information

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from: unauthorised access; improper use or disclosure; unauthorised modification; and unlawful destruction or accidental loss.

All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal information are obliged to respect the confidentiality of the personal information of all users of our Site and our Services.

How to access your information and your other rights

You have the following rights in relation to the personal information we hold about you: Your right of access. If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.

Your right to rectification

If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to erasure

You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

Your right to restrict processing

You can ask us to block or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information, though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

Your right to data portability

You have the right, in certain circumstances, to obtain personal information you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice. Your right to object. You can ask us to stop processing your personal information, and we will do so, if we are: relying on our own or someone else’s legitimate interest to process your personal information, except if we can demonstrate compelling legal grounds for the processing; processing your personal information for the purposes of personalised direct marketing; or processing your personal information for the purposes of non-personalised direct marketing.

Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email. 

Your right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, please contact us using the contact details provided in the “How to Contact Us” section above.

You can also report any issues or concerns to the Information Commissioner’s Office (ICO). You can find details about how to report a concern on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

Changes to this Privacy Notice

We may make changes to this Privacy Notice from time to time. To ensure that you are always aware of how we use your personal information we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by email of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.