Data Policy - INTRODUCTION
1.1 We are INTOUCH TEAM LIMITED (referred to as "we", “us” and “InTouch”) and we are committed to protecting and respecting your privacy when you are visiting any website (including the coaches portal) or mobile application maintained by us including without limitation our social networking pages (together the “Website”) or communicating electronically with us or taking part in any InTouch activity.
1.2 This policy, together with the Terms and Conditions (which can be found on our website at www.in.io/general-terms) explains what types of personal and non-personal information we collect when you use the coaches portal, mobile applications, or website and provide us with any information in the context of taking part in any InTouch activity. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
1.3 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By disclosing your personal information to us by using the website, coaches portal or mobile applications or speaking to us over the telephone you consent to the collection, storage and processing of your personal information as stated in this policy.
1.4 InTouch uses the personal information we collect from you to provide our service to you. We will not rent, sell or share your personal information with any other company for its own marketing purposes without your consent except where mentioned in this policy.
1.5 For the purpose of the Data Protection Act 1998 (the Act), the data controller is InTouch Team Limited of 13 Queens Road, Bournemouth BH26BA which is registered with the ICO with registered number A8095480.
WHAT PERSONAL INFORMATION DO WE COLLECT?
2.1 We may collect, store and use the following kinds of personal information:
1 when you register as a user of the Website, Coaches portal or mobile application and/or to become a member of a InTouch group, you may be asked to complete a form which will give you the option to provide some or all of your name, address, date of birth, email address, telephone number, and certain other personal information about you to enable us to perform compliance checks on you;
2 when you contact us by email or telephone or through any contact form provided on the Website, or if you provide us with information when you take part in a InTouch task we may ask you to provide some or all of the information set out in paragraph (2.1.1) above as well as any additional information required so that we can best assist you with your enquiry;
3 we may collect, store and use information about your computer, mobile device or other item of hardware through which you access the Website, coaches portal or mobile applications and your visits to and use of the Website, coaches portal or mobile applications (including without limitation your IP address, geographical location, browser/platform type and version, Internet Service Provider, operating system, referral source/exit pages, length of visit, page views, navigation and search terms that you use); and
4 if you access the Website, coaches portal or mobile applications through a social networking profile, we may collect, store and use the details of that social networking profile and any information contained therein in order to populate any forms you might wish to complete on the Website.
2.2 We may also ask you to complete surveys and give feedback that we use for research purposes, although you do not have to respond to them.
2.3 If you choose to provide us with information on other people, or post information relating to other people, you must ensure that they have consented to you providing us with such information and our use of such information in accordance with this policy. By providing us with information on any other person, we are entitled to assume that such other person has consented to you providing us with their information and to us contacting them. Notwithstanding the previous sentence, if you have any concerns or issues with or about any other member or vulnerable person with whom you interact as part of any InTouch task you must tell us your concerns and any further information necessary for us to take any steps necessary and practicable (in our sole and absolute discretion) to protect any person or prevent any harm to any person whether or not the person to whom the information relates has consented to such disclosure. You must not publish any such information online without our prior written consent.
HOW DO WE USE PERSONAL INFORMATION?
3.1 We may use your personal information for the following purposes:
1 to manage and administer the Website, coaches portal, mobile applications and any InTouch tasks that you have agreed to undertake;
2 to improve your browsing experience by personalising the Website, coaches portal or mobile applications;
3 to enable you to use the Website, coaches portal or mobile applications;
4 to deal with enquiries, complaints and feedback from you and people with whom you have interacted as part of your involvement with InTouch;
5 to provide third parties with statistical anonymised information about our users;
6 to send you emails; and
7 to analyse and improve the services offered by us.
WHEN MIGHT WE DISCLOSE PERSONAL INFORMATION?
4.1 We reserve the right to disclose your personal information to the extent required by any applicable law or governmental body or judicial body. In addition, we may from time to time provide limited anonymised information relating to your usage and browsing habits on the Website, coaches portal and mobile applications to third parties. Without limitation, we may disclose any information relating to your behaviour and any other information we consider in our sole and absolute discretion to be relevant where we believe that you have, or may in the future, commit any criminal offence in the context of your relationship with InTouch.
4.2 We will use all reasonable endeavours to ensure that any person to whom we disclose confidential information is compliant with the Data Protection Act 1998 (or an equivalent standard) as regards its use and storage of your personal information. In particular, our contracts with product advertisers and third party providers state that they may use personal information relating to our customers disclosed to them by us solely for the purposes of providing services to our customers and that they may not disclose or otherwise use any such personal information for any other purpose.
NEWSLETTERS AND OTHER PROMOTIONAL COMMUNICATIONS
5.1 If you wish to subscribe to any newsletter published by us or wish to receive other targeted and relevant promotional communications from us or other carefully chosen affiliates, we offer you the option to “opt-out” to this service. If you wish to stop receiving any such communications, please email us at firstname.lastname@example.org.
6.1 Cookies are text files stored, either on a temporary or persistent basis on the hard drive of your computer or mobile device. Cookies are used for authenticating, session tracking and maintaining specific information about the use and users of the Website, coaches portal and mobile applications (including user site preferences or the contents of electronic shopping carts). Cookie files may also be placed on your computer or mobile device by our trusted third-party advertising companies for the purposes as set out in this paragraph.
6.2 You can delete all cookies that are already on your computer's hard drive by searching for files with "cookie" in it and deleting them. In addition, if you want to stop cookies from being stored on your computer, you can edit your browser settings so that cookies are blocked. Unfortunately, if you block cookies you may not be able to use the full functionality of the Website, coaches portal or mobile applications. For more information about cookies, please visit: www.allaboutcookies.org
6.3 Web beacons consist of a small string of software code that represents a graphic image request on a Web page or email. There may or may not be a visible graphic image associated with the web beacon and often the image is designed to blend into the background of a Web page or email. Web beacons can be used for many purposes - including site traffic reporting, unique visitor counts, advertising auditing and reporting, and personalisation. Web beacons may be used by InTouch.
6.5 In order to understand how people use our services and for marketing analysis and quality improvement purposes, we (and/or third party service providers) may collect, record, process and use certain information (including the total number of transactions, viewed web pages, referring/exit pages, platform type, date/time stamp information and details like the number and location of mouse clicks on a given page, mouse movements, scrolling activity and the search words you use while being on and using the Website.
WHERE WE STORE YOUR PERSONAL DATA
7.2 All information you provide to us is stored on our secure servers.
7.3 Unfortunately, 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 transmitted through our Website, coaches portal or mobile applications; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7.4 We transmit personal information using Secure Sockets Layer (SSL) software which encrypts information you input. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
7.5 It is important that you protect against unauthorised use of your password and username to the Website, coaches portal or mobile applications.
8.1 The Act gives you the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing at any time by contacting us at email@example.com.
8.2 The Website, coaches portal or mobile applications may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
ACCESS TO INFORMATION
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.