Privacy Notice

Our Website is not intended for children and we do not knowingly collect data relating to children.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (paragraph 8), please contact us using the information set out in the contact details section (paragraph 12).

If you are an individual residing in the European Economic Area (EEA), in compliance with the EU General Data Protection Regulation (GDPR) we have appointed a European authorised representative to act as our direct contact for data subjects, the European Union (EU) and EEA supervisory authorities. You can contact our authorised representative using the details set out in paragraph 9 if you have any questions or concerns related to your personal data.

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1. The types of personal data we collect about you

Personal data means any information about an individual from which that individual can be identified.

We may collect, use, store and transfer (collectively “process”) different kinds of personal data about you which includes but is not limited to the following:

• Identity Data: first name, last name, job title.
• Contact Data: email address and telephone numbers.
• Communications Data: if you contact us (including submitting any enquiries), a record of our correspondence with you.
• Transaction Data: details about payments to and from you and other details of services you have purchased from us.
• Special Data: any dietary information or special arrangements you have requested.
• Events Data: photos and videos taken of you during events and conferences.
• Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location (but not your precise geolocation), browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the Website and Platform.
• Login Data: your username and any password provided by us to access our Platform or any other services.
• Profile Data: purchases made by you, your interests, preferences, feedback, testimonials and responses to surveys sent by us (these are optional, you do not have to respond to them).
• Usage Data: information about how you interact with and use our Website, Platform and/or other services.
• Marketing Data: your preferences in receiving marketing from us and our third parties and your communication preferences.

Photos or videos of you on may be shared on our Website, Platform and social media channels. You should be aware that any photos or videos published on the Website or social media channels will be accessible to millions of users across the world and it may be copied, shared and used by any internet user (which could be outside our control). This means that once a photo or video is published on the internet, we may not have control over its subsequent use and disclosure. If you are concerned about our use of your personal data in this way, please contact us using the details provided in paragraph 12 below.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website and/or Platform feature in order to analyse general trends in how users are interacting with our Website and Platform to help improve the Website, Platform and our service offering.

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2. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data as set out in section 1 above by filling in online forms e.g. our member application form, or by corresponding with us by post, phone, email or otherwise.
• Automated technologies or interactions. As you interact with our Website and Platform, we may collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies but only if you accept the relevant cookies via the cookie controls available when you first open our Website. Please see our Cookie Policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  
  • Technical Data is collected from analytics providers such as Google [based outside the UK];
  • Identity and Contact Data may be collected from publicly available sources such as company registries local to you (such as Companies House in the UK), and your organisation’s website;
  • Identity and Contact Data may be collected from your member organisation. Disclosure by your member organisation will be subject to their privacy policies. If you have concerns regarding their disclosure of your personal data to us, you should contact your member organisation.

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3. How we use your personal data

3.1 Legal bases

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you / your member organisation: Where we need your personal data in order to perform the contract we are about to enter into or have entered into with you / your member organisation.
• Legitimate interests: We may use your personal data where necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation to which we are subject. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you provide us with your Health Data; or where you are not an Authorised Staff member but you choose to subscribe to our marketing.

3.2 Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of 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.

3.3 Direct marketing

• During the registration process on our Website or Platform when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from IPG via email. You will receive marketing communications from us if you are an Authorised Staff member and/or have requested information from us or purchased services from us and you have not opted out of receiving the marketing.
• Subject to above, we may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view about which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

3.4 Third-party marketing

We will not share your personal data with third parties other than for our own purposes. If we intend to do so, we will get your express consent before we share your personal data with any third party for their own direct marketing purposes.‍

3.5 Opting out of marketing

If you are not Authorised Staff and do not or no longer want us to use your personal data for marketing, you may unsubscribe at any time by following the opt-out links or other process set out within any marketing communication sent to you or by contacting us using the contact details set out in paragraph 12 below. If you are Authorised Staff, you cannot opt out because the purpose of IPG is to provide such marketing communications among other services, and you should not join IPG if you do not want to receive these.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to confirmations for a service, events and conferences including reminders, updates to our Website and Platform Terms of Use, checking that your contact details are correct.

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4. Disclosures of your personal data

We may share your personal data (only where necessary) as follows:

• our third-party services providers, agents, or sub-contractors for the purposes of providing parts of our services to you on our behalf (e.g. to host our Website, Platform, social media channels to promote our content and services, to process payments, to send you marketing communications);
• 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 privacy policy which they may amend to align with their own;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website and Platform Terms of Use or other agreements;
• to protect the rights, property or safety of IPG, the Website and Platform, our users and any third party we have engaged to provide our Website, Platform and services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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5. International transfers

We currently do not transfer your personal data outside the United Kingdom (UK) and/or the European Economic Area (EEA). Some IPG events take place outside the UK and EEA, but personal data processed for those events are processed by the event organiser directly and in accordance with their own privacy policy.

In future, if we should transfer your personal data out of the UK and/or EEA to countries which have laws that do not provide the same level of data protection as the UK and/or EEA, we will ensure that a similar degree of protection is afforded to it by ensuring that adequate safeguards compliant with the current applicable data protection laws are implemented.

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6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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7. Data retention

For how long will you use my personal data?

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.

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease to be customers for tax purposes.

In some circumstances you can ask us to delete your data: see paragraph 8 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.

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8. Your legal rights

8.3 You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "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.
• 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.
• Request erasure of your personal data in certain circumstances. 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.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see paragraph 3 for details of how to object to receiving direct marketing communications).
• 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.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in paragraph 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  
  • If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us using the details provided in paragraph 12 below.

8.2 No fee usually required

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.‍

8.3 What we may need from you

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.

8.4 Time limit to respond

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.

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9. Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy policy under regular review. Any changes we make to our Privacy Policy in the future will be notified to you and made available via our Website and additionally via the email address you have used to register to our Platform, if you are an Authorised Staff member. You should ensure you are happy with any changes to this Privacy Policy and your continued use of our Website, Platform and services shall be deemed as your acceptance of the varied Privacy Policy.

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 (for example a new address or email address) using the contact details in paragraph 12 below or by updating your personal details within your dashboard on the Platform.

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10. Third-party links

This Website 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 Website, we encourage you to read the privacy policy of every website you visit.

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11. Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy.

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12. Contact details

If you have any questions about this Privacy Policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

For individuals located in the UK:

Email address: elke.bockisch@ipg-online.org

Postal address:

International Practice Group,
Leytonstone House,
3 Hanbury Drive,
London E11 1GA

For individuals located in the EEA:

Name of authorised representative: [insert details]

Postal address: [insert details]

Email address: [insert details]

Telephone: [insert details]

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13. Complaints

We hope that we can resolve any query or concern you may wish to raise about our use of your personal data. Please contact us or our authorised EU representative in the first instance with your queries/concerns. However, if you are not satisfied with the response or the manner in which we or our authorised representative has handled your queries/concerns or your personal data, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk), if you are an individual located in the UK, or to the relevant supervisory authority for the country in which our authorised EU representative is located, if you are an individual located in the EEA.