This policy sets out how we TheIPG Ltd ("The IPG/we/our/us") may collect personal data from you, when we may collect personal data from you, the type of personal data and/or sensitive personal data we may collect from you or that you provide to us, and how such data may be controlled and/or processed once you use or access features on the www.the-ipg.co.uk website.
This policy also sets out your rights and our obligations concerning collecting, controlling, and processing such personal data.
Our main objective is for you to have absolute trust and confidence in us when we collect, control and process your data.
Any third-party data processors must comply with this policy when processing personal data on our behalf.
Any breach of this policy by that third party may result in disciplinary action being taken against them.
1. Who We Are
The IPG is registered in England and Wales with the company number 08749971.
Our registered office address is:
Under the Data Protection Act 1998 ("the Act") and General Data Protection Regulation (Regulation (EU) 2016/679) ("the Regulation"), we are a data controller and data processor of personal data and sensitive personal data provided by you to us through our website.
Our ICO registration reference is: ZA280769.
2. Our Commitment
At The IPG we are as committed to protecting your data as we are to servicing and supporting our client's needs.
We take tangible steps to keep your data private and confidential. These steps include:
- Being completely transparent about how, when and why your data is controlled and processed by us.
- Allowing you control over the personal data we collect from you and how we process that personal data.
- If you choose to allow us to process your data, we will make as clear as possible the reasons why and how that data may be collected, used and transferred.
3. What is Personal Data?
Personal data is information about an "identified" person or an "identifiable natural person".
An "identifiable natural person" can be identified, directly or indirectly, in particular reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
Sensitive personal data includes, but is not limited to, personal data which reveals racial or ethnic origin.
4. Personal Data We May Control and Process
We may collect and process personal data, sensitive personal data and other information from you when you use our website and its content and when you correspond with us by phone, email or otherwise.
The type of data collected and how such data is collected will vary depending on how you use our website and whether or not you have consented for us to collect certain types of data from you.
By using our website and/or our products or services in conjunction with our website, you agree that we collect and process the personal data provided as part of that process for the purposes made clear to you at that time.
5. How We Collect Personal Data
Personal and sensitive personal data may be collected by us actively and passively. The specific types of personal data we may collect from you are detailed below.
This is data we must collect to provide you with access to content found on our website, as well as to enable you to access and use that content across multiple devices, to enable you to delete personal data when you wish, and/or for us to deliver information, content or services that you request through the website.
We may also use Necessary Data to provide you with information about similar products and services we provide.
Necessary Data includes but is not limited to your name, email address and company information.
Necessary data will be collected by us when you fill in and submit the relevant form through the website.
This data includes information not necessary for us to collect but which you actively provide to us ("Optional Data").
Optional Data includes but is not limited to information about your business and the reasons for using the website or company information.
We may also use Optional Data to analyse your requirements as a consumer and provide information about other products and services we provide that may interest you.
Optional Data will be collected by us when you submit a request for content through forms throughout the website which request that data.
You may be able to actively provide us, at any time in the future, with additional Optional Data if you choose to do so. We will collect and use that data following these terms.
When you enter a competition we host and you provide Necessary and/or Optional Data, whether on our website, in collaboration with third parties or on social media platforms such as Facebook, you agree to be contacted by The IPG and its members with information relevant to your profession.
While collaborating with third parties, we handle your data carefully and do not solely rely on external privacy policies. Our commitment is to use the data provided transparently and appropriately.
We may collect Device Information using the following technologies:
- "Cookies" are data files placed on your device or computer and often include a unique anonymous identifier. For more information about cookies and how to disable cookies, visit http://www.allaboutcookies.org.
- "Log files" track actions occurring on the website and collect data, including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- "Web beacons," "tags," and "pixels" are electronic files used to record information about how you browse the site.
We passively collect this data while you use and browse the website.
When you visit the website, we may automatically collect certain information about your device, including your web browser, time zone, and some of the cookies installed on your device.
In some cases, the information we collect – for example, your device information – can be used to help us improve and optimise our website.
We may also collect information about the web pages you view, what websites or search terms referred you to, and how you interact with the website.
For example, this information might be by generating analytics about how our visitors browse and interact with the website and assessing the success of any marketing and advertising campaigns.
6. How We Use Your Personal Data
We may use Necessary Data to provide content after you have requested it by filling in a form or creating your member account so you can gain full access to the website and its content.
For instance, when requesting content on our website, you provide us with your phone number to help our internal teams respond to your requests.
We may also use website data to understand how our clients behave for us to develop or optimise:
- How the website works for you;
- The information and services provided to you through our website; and
- The effectiveness of our online advertising and branding.
All personal data we collect and process is stored on our secure servers following reasonable security practices.
7. Your Rights and Our Obligations
We will process your data with your express consent through opt-in mechanisms.
For example, we may be able to legally control and process your personal data without your express consent for direct marketing purposes if doing so is in the public interest, where it is necessary for the performance of a contract, or if we must do so to comply with local or national law.
We may also process your personal data without your express written consent if we have a legitimate interest in doing so, for some internal administrative purposes, or to ensure electronic information security.
Where we are processing your personal data based on you giving us your consent to do so, you have the right to withdraw that consent at any time, but this will not affect the lawfulness of the processing before the withdrawal of such consent.
You can exercise your right to withdraw consent to the processing at any time by contacting us via firstname.lastname@example.org
Data Retention, Erasure and Rectification
The personal data we collect from you will be stored and retained by us for the time necessary to fulfil our services.
We may also retain such data for a reasonable period after our engagements have ended to keep a record of our communications and how you have used the website or for any period as required by applicable law.
You have the right to erasure (the 'right to be forgotten').
This means that you have the right to request us to erase personal data we hold about you and that we should erase such data without undue delay, if any of the below are applicable:
- That our processing of personal data is no longer necessary in relation to the purpose for which it was collected;
- That you withdraw your consent to the processing, and there is no other legal ground for us to continue to process the data;
- That you object to the processing under regulation 21 of the Regulation and there are no overriding legitimate grounds for the processing;
- That the personal data must be erased to comply with a national legal obligation; or
You also benefit from the right to rectify inaccurate personal data we hold which relates to you (also known as the 'right to rectification').
You can exercise your rights to erasure and rectification by contacting us via email@example.com
8. Sharing and Transferring Personal Data
We use industry-standard encryption for the transmission of data to our systems. Although we cannot guarantee the absolute safety of data transmission via the Internet, we adhere to industry standards to give your data the most appropriate protection possible.
Sharing of Personal Data
- We may share data we hold with any member of our group, as defined in section 1159 of the UK Companies Act 2006.
- Our group is any supply partner or independent store registered with The IPG.
The data shared may include names and email addresses related to the data subjects profession.
This information will not be passed on to any parties outside the group.
We may also disclose personal data we hold to third parties, with your consent or based on an otherwise lawful reason for doing so under the Legislation. For example:
- To facilitate, provide and improve the products and services we provide to you through our website;
- To analyse how our services are used by clients;
- In the event that we sell or buy any business or assets, in which case we may disclose personal data we hold to the prospective seller or buyer of such business or assets;
- If we or substantially all of our assets are acquired by a third party, in which case personal data we hold will be one of the transferred assets; and
- 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 any contract with the data subject or other agreements, or to protect our rights, property, or safety of our employees, customers, or others.
- This includes exchanging information for fraud protection and credit risk reduction with other companies and organisations.
9. Use of Third-Party Platforms
Our Platforms use Google Analytics, a web analytics service offered by Google, LLC.
Google Analytics uses small pieces of data, known as cookies, which can be used to track and analyse how you use and operate our Platforms.
Such data will be transferred to and stored on a server in the USA operated by Google, LLC who may transfer this data to third parties where required by law or other third-party processors used by Google, LLC.
Google Analytics cannot be used to create User Profiles or track individual activity across the Internet. For more information, please visit this link.
Our Platforms may utilise Google Ads, an online advertising service provided by Google, LLC.
Google Ads uses technologies like HTML5 for interactive ad formats and may use the IP address to identify your general location.
Google Ads employs cookies and other technologies to display targeted advertisements based on your interactions with our Platforms and other websites.
This data is transferred to servers operated by Google, LLC in the USA. Google may share this data with third parties when required by law or with affiliated third-party processors.
Google Ads products may also infer information about your location from various sources, such as search queries or websites you visit. Google ensures that ads are safe, discreet, and relevant.
We may also use Facebook's advertising platform and its accompanying service, "Facebook lookalike audiences".
Facebook lookalike will allow us to identify new potential consumers and users of our Platforms and products because those new potential users share similar characteristics with you on Facebook.
For example, on the basis that both users have "liked" the same Facebook pages.
We may, therefore, share your email address and name with Facebook if you have logged into the Platforms via your Facebook account or have downloaded our Platforms onto your device through a Facebook advertisement.
More information about Facebook advertising and lookalike audiences is here.
We use the information gathered to improve our website functionality and user experience and tailor our content.
HubSpot uses log files which may collect demographic information from you, for example, age, gender or interests.
HubSpot may also collect information about your computer hardware and software.
This can include your IP addresses, device and software identifiers, referring and exit URLs, on-site behaviour, feature use metrics and statistics.
For these purposes, we link this automatically collected data to Personal Information such as name, email address and phone number.
We may collect navigational information when you visit HubSpot-hosted pages.
The navigational information is used to improve your website experience and ease navigation around the site.
The HubSpot Acceptable Use Policy applies to our website and prohibits using our website to send unsolicited commercial emails violating applicable laws, and requires the inclusion in every email sent using the Subscription Service to have an "opt-out" mechanism.
Pages of our website are hosted in England and by HubSpot, whose registered address is:
25 First Street
Data captured and obtained within the UK may be processed outside the UK.
When interacting with us on social media, your username and public-facing information are available for us to view.
You have the right to request that we remove this information. However, please be aware that as the data is transferred from the social networks, it may not be feasible to delete the information fully.
Other Third Party Platforms
Our website may incorporate embedded assets from third parties, including but not limited to:
- YouTube videos
- Google Maps
- Other third-party integrations
These embedded assets may collect data or set cookies on your device. We recommend reviewing the privacy policies of these third-party providers to understand how they manage data.
If you wish to avoid potential data collection from these assets, consider using browser settings or extensions to block third-party cookies or scripts.
10. Transfers Outside of the EEA
We may also transfer any personal data we hold to a country outside the European Economic Area (EEA), provided that one of the following conditions applies:
- The country to which the personal data is transferred ensures an adequate level of protection for the data subjects' rights and freedoms;
- You have given your consent;
- The transfer is necessary for one of the reasons set out in the Act and/or Regulation, including the protection of your vital interests;
- The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims; o
- The transfer is authorised by the relevant data protection authority, where we have adduced adequate safeguards with respect to the protection of the data subjects' privacy, their fundamental rights and freedoms, and the exercise of their rights.
11. External Links
When you click on links on our website, they may direct you away from our site.
We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
12. Your Rights and Our Obligations
You have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format.
You have the right to transmit such data to other data controllers without hindrance from us where we are processing that data based on having your consent to do so or where it is necessary for the performance of a contract and the processing is carried out by automated means.
Subject Access Requests
As a data subject, you are entitled to formally request information we hold about you.
We must provide you with a copy of this information, the reasons it is being processed and whether it will be given to any other organisations or people, provided that you make this request in writing.
How Do I Withdraw My Consent or Make a Subject Access Request?
If you are a UK resident, you have the right to access the personal information we hold about you and to ask that your personal information be corrected, updated, or deleted.
You have the following rights concerning your data:
- You have the right to know why your personal data is needed, what will happen to it, and how long it will be retained.
- Right of access: You have the right to access your personal data that is known to us.
- Right to rectification: You can supplement, correct, delete, or block your personal data.
- If you give us your consent to process your data, you have the right to revoke that consent and to have your personal data deleted.
- Right to transfer your data: You have the right to request all your personal data from the controller and transfer it to another controller.
- Right to object: You may object to the processing of your data. We comply with this unless there are justified grounds for processing.
You can read more about Subject Access Requests at the Information Commissioner's Office website.
Any marketing information we provide you has Opt-Out and unsubscribe options.
You can blanket opt out of any tracking using tools such as Google Analytics, a browser add-on, and tools such as Stands Blocker, depending on your browser type and preferred configuration.
You may prevent cookies from being stored concerning your visit to and use of our platforms, but please be aware that this may negatively impact how the platforms work.
13. Children's Privacy
The goods and services provided through our website are not marketed to, and should not be used by, anybody under the age of 18.
We do not knowingly collect personal data from children under 18.
If we discover that a child under 18 has provided us with personal data, we will delete such data from our servers unless consent is given or authorised by the holder of parental responsibility over the child.
14. Changes to this Policy
We reserve the right to change this policy at any time. Where appropriate, we will notify you, as a data subject, of those changes by email.
15. Concerns or Complaints
If you have any concerns or complaints relating to this policy, its subject matter, or how we collect, control and/or process your personal data, please do let us know by sending an email to firstname.lastname@example.org