Privacy and Cookies Policy
Privacy & Copyright Policy Insperanto Limited
Last updated May 2020
Last updated May 2020
Background:Insperanto Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.insperanto.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
- Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 and EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means Insperanto Limited, a limited company registered in England under company number 12172027, whose registered address is 19-20 Bourne Court, Southend Road, Woodford Green, Essex LG8 8HD and whose trading address is Kemp House, 152-160 City Road, London EC1V 2NX, UK
- Information About Us
Our Site is owned and operated by Insperanto Limited, a limited company registered in England under company number 12172027, whose registered address is 19-20 Bourne Court, Southend Road, Woodford Green, Essex LG8 8HD and whose trading address is Kemp House, 152-160 City Road, London EC1V 2NX, UK.
Our VAT number is 347809565
- What Does This Policy Cover?
As a data subject, you have the following rights under the GDPR and the Data Protection Act 2018, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 15);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 15);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 15 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
- What Data Do We Collect?
5.2 date of birth;
5.3 business/company name;
5.4 job title;
5.6 contact information such as email addresses and telephone numbers;
5.7 demographic information such as post code, preferences, and interests; and
5.8 IP address.
How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR and the Data Protection Act 2018 at all times. For more details on security see section 7, below.
Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Site;
6.2.3 Personalising and tailoring your experience on Our Site;
6.2.4 Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Personalising and tailoring Our services for you;
6.2.6 Replying to emails from you; and
6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by unsubscribing to any newsletters We may send to you);
With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email telephone, text message or post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR, Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
We will retain all information that is necessary for us to perform our services and for a period of 12 months thereafter unless we are required to retain any information for longer as required by Statute.
We will retain your contact information such as email address, phone number and postal address for a period of 12 months following any cancellation of Our services unless we are required to retain any information for longer as required by Statute.
- How and Where Do We Store Your Data?
We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it. 7.2
We store or transfer some of your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation. 7.3
We store or transfer some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
We may store or transfer 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 we 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.
Your information may be transferred to, stored, or processed Worldwide in Countries such as the United States which are not currently a member of the EU’s “third countries”. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy. We will sufficiently protect data by way of standard contract clauses.
Steps We take to secure and protect your data include:
7.6.1 Password protection on all devices and cloud storage that store your personal data
7.6.2 We only store your data on computers and devices owned by Us. We may also use Contractors who may store Our data on their computers, servers and any such cloud storage they may use, such as IT companies that provide us with technical support services. We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
7.6.3 All our computers and devices have anti-virus software and up to date operating systems to limit any unauthorised access
- Do We Share Your Data?
We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
- What Happens If Our Business Changes Hands?
In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
- How Can You Control Your Data?
In addition to your rights under the GDPR and the Data Protection Act 2018, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- Your Right to Withhold Information
You may access certain areas of Our Site without providing any data at all.
- How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com or using the contact details below in section 15.
A cookie is a small simple file that is sent along with pages of this website and stored by your browser on the hard drive of your computer or another device. The information stored therein may be returned to our servers or to the servers of the relevant third parties during a subsequent visit.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third Party Cookies are used on Our Site for the compliance of the Cookie consent banner. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies
Technical or functional cookies ensure that certain parts of the website work properly and that your user preferences remain known. By placing functional cookies, we make it easier for you to visit our website. This way, you do not need to repeatedly enter the same information when visiting our website. We may place these cookies without your consent.
We use analytical cookies to optimize the website experience for our users. With these analytical cookies we get insights in the usage of our website. We ask your permission to place analytical cookies.
The following first party Cookies may be placed on your computer or device:
Name of Cookie: Elementor
Purpose: Content creation.Store performed actions on the website.
Name of Cookie: SiteGround wpSGCacheBypass
Purpose: Functional for web hosting.
Name of Cookie: Wordfence wfwaf-authcookie-*
Purpose: Website security. Determine if the user is logged in
Retention: 12 hours
Name of Cookie: Google Fonts API
Purpose: Display webfonts. Request user IP address
Name of Cookie: e_site-editor
Name of Cookie:e_globals
and the following third-party Cookies may be placed on your computer or device:
We do not currently run any third-party cookies. We will update this policy if we do decide to add any.
In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
- Children’s Privacy
We do not knowingly collect or solicit information from anyone under the age of 16 or knowingly allow such persons to register for Our services. This site and its contents are not directed at children under the age of 16. In the event that We learn that we have collected personal information from a child under the age of 16 without parental consent We will delete that information as quickly as possible. If you believe that We might have any information from or about a child please contact Us.
- Contacting Us
Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).