1. Information About Intelpool Limited
This Site is owned and operated by Intelpool Limited, a limited company incorporated in England and Wales under company number 12089094.
Registered address: Apollo House, Hallam Way, Whitehills Business Park, Blackpool, United Kingdom, FY4 5FS.
Our Data Protection Officer’s email address is firstname.lastname@example.org
2. What Does This Policy Cover?
3. What Is Personal Data?
Personal data is defined by the European Union’s (EU) General Data Protection Regulation 2016/679 (the “GDPR”) and the United Kingdom (UK) Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simple terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights which, as a commitment to Intelpool Limited's corporate responsibility and our overall ethical standards, the Company will always work to uphold:
- The right to access the personal data the Company holds about you. PART 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by the Company is inaccurate or incomplete. Please contact the Company using the details in PART 11 to find out more.
- The right to be forgotten, i.e. the right to ask the Company to delete or otherwise dispose of any of your personal data that it holds. Please contact the Company using the details in PART 11 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to the Company using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if the Company is relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to the Company directly, Intelpool Limited is using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask the Company for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. The Company does not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact Intelpool Limited using the details provided in PART 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data the Company holds about you changes, please keep Intelpool Limited informed as long as the Company has that data.
If you have any cause for complaint about the Company's use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). Please be aware that the ICO (upon receiving a new complaint) is unlikely to review the matter unless you have raised it with the organisation subject of your complaint first. The Company would welcome the opportunity to resolve your concerns itself, so please contact Intelpool Limited first, using the details in PART 11.
5. What Personal Data Do You Collect and How?
Subject to the following, Intelpool Limited does not collect any personal data from you, nor does the Company directly collect, store or use any metadata; also known as communications data or log information. The Company does not place cookies on your computer or device, nor does the Company use any other means of data collection.
This Site collects certain information automatically, including your IP address, the type of browser you are using, and certain other non-personal data about your computer or device such as your operating system type or version, and display resolution. This information is held by the Company's server provider and is not examined.
If you send Intelpool Limited an email, the Company may collect your name, your email address, and any other information which you choose to share. For the purposes of the Data Protection Legislation, Intelpool Limited is the data controller responsible for such personal data.
The lawful basis under the Data Protection Legislation that allows Intelpool Limited to use such information is article 6(1)(f) of the GDPR, which allows the Company to process personal data when it is necessary for the purposes of the Company's legitimate interests, in this case, the proper operation and functionality of this Site. If you contact Intelpool Limited as described above, you will be required to consent to the Company's use of your personal data to contact you. In this case, Intelpool Limited's lawful basis for using your personal data will be article 6(1)(a) of the GDPR, which allows the Company to use your personal data with your consent for a particular purpose or purposes.
6. How Do You Use My Personal Data?
Where Intelpool Limited collects any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. Intelpool Limited will comply with the Company's obligations and strictly safeguard your rights under the Data Protection Legislation at all times. For more details on security see PART 8, below.
As stated above, Intelpool Limited does not generally collect any personal data directly from you, but if you contact Intelpool Limited and the Company obtains your personal details from your email, Intelpool Limited may use them to respond to your email. The other technical data referred to above is necessary for the technical operation of this Site and will not normally be used in any way to personally identify you.
Intelpool Limited does not share any of your personal data with any third parties or organisations for any purpose, other than storage on an email and/or web hosting server. For more details on data storage, see PART 9, below.
7 How Long Do You Keep My Personal Data?
Intelpool Limited uses reasonable efforts to retain personal data collected from you for no longer than is necessary for the purpose(s) it was provided for and to meet any legal responsibilities or obligations, or until the Company is requested to delete it (if earlier).
8. How and Where Do You Store My Data?
Intelpool Limited may store some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that Intelpool Limited will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
Intelpool Limited may store your data with external third parties, as detailed below in PART 9, that are based outside of the EEA. The following safeguards are applied:
- Intelpool Limited will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.
- Where Intelpool Limited transfers your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact Intelpool Limited using the details below in PART 11 for further information about the particular data protection mechanisms used by the Company when transferring your personal data to a third country.
Intelpool Limited is committed to ensuring that your information is secure. In order to protect personal data and prevent its unauthorised access or disclosure, the Company takes the following measures:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where the Company is legally required to do so;
- implementing reasonable commercial standards of technology and operational security to protect all information provided by visitors via this website from unauthorised access, disclosure, alteration, or destruction;
- implementing suitable physical, electronic and managerial procedures to safeguard and secure the information the Company collects online from loss, misuse, alteration, or destruction.
9. Do You Share My Personal Data?
Intelpool Limited may contract with third parties for hosting and data storage purposes.
If any of your personal data is transferred to a third party, as described above, Intelpool Limited will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in PART 8.
If any personal data is transferred outside of the EEA, Intelpool Limited will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in PART 8.
In some limited circumstances, Intelpool Limited may be legally required to share certain personal data, which might include yours, if Intelpool Limited is involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data Intelpool Limited has about you, you can ask the Company for details of that personal data and for a copy of it (where any such personal data is held). This is known as a Data Subject Access Request (“DSAR”).
All subject access requests should be made in writing and sent to the email address shown in PART 11.
There is not normally any charge for a DSAR. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover the Company's administrative costs in responding.
Intelpool Limited will act on your DSAR without undue delay and respond to it within one month of receiving it. Normally, the Company aims to provide a complete response, including a copy of your personal data, within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date the Company receives your request. You will be kept fully informed of the Company's progress.
11. How Do I Contact You?
To contact Intelpool Limited about anything to do with your personal data and data protection, including to make a Data Subject Access Request, please send an email to the Company's Data Protection Officer at email@example.com
Intelpool Limited recommends that you check this page regularly to keep up-to-date.
This policy will be reviewed at least annually unless legislative or regulatory changes require it to be reviewed earlier before this date.