PRIVACY POLICY

Last revised February 2023
© iNREACH Group Limited. 2023. All rights reserved.

Introduction

iNREACH Group takes your privacy very seriously. This Privacy Notice is intended to set out your rights and answer any queries you may have about your personal data. If you need more information, please email enquiries@inreachgroup.co.uk

1. What information do we collect?

We collect and process personal data about you when you interact with us and our products, and when you purchase goods and services from us. The personal data we process can include:

• Your name;
• Your username and password;
• Your work address, email address and/or phone number;
• Card payment details;
• Your job title;
• Your payment and delivery details, including billing and delivery addresses; and/or
• Any other information you provide.

2. How do we use this information and what is the legal basis for this use?

We process the personal data listed above in paragraph 1 for the following purposes:

• As required to establish and fulfil a contract with you, for example, if you make a purchase from us or enter into an agreement to provide or receive services. This may include verifying your identity, taking payments, communicating with you, providing customer services and arranging the delivery or other provision of products or services. We require this information in order to enter into a contract with you and are unable to do so without it;
• To comply with applicable law and regulation;
• In accordance with our legitimate interests in protecting iNREACH Group’s legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation);
• With your express consent to respond to any comments or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our products or services;
• We may use information you provide to personalise:
  (i) Our communications to you; and
  (ii) Products or services for you, in accordance with our legitimate interests;
• To monitor use of our websites and online services. We may use your information to help us check, improve and protect our products, content, services and websites, both online and offline, in accordance with our legitimate interests;
• If you provide a credit or debit card, we may also use third parties (such as POS payment providers) to check the validity of the sort code, account number and card number you submit in order to prevent fraud, in accordance with our legitimate interests and those of third parties;
• We may monitor any customer or supplier account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law and our legitimate interests;
• In circumstances where you contact us by telephone, calls may be recorded for quality, training and security purposes, in accordance with our legitimate interests; and
• We may use your information to invite you to take part in market research or surveys.

We may also send you direct marketing in relation to relevant products and services. Electronic direct marketing will only be sent where you have given your consent to receive it or we believe there is a legitimate interest in the information it contains, or (where this is allowed) you have been given an opportunity to opt-out. You will continue to be able to opt-out of electronic direct marketing at any time by following the instructions in the relevant communication.

3. With whom and where will we share your personal data?

We may share your personal data with our group companies to process it for the purposes of inter-group administration and to deliver products or services where elements of these are provided by group companies other than those with which you have directly contacted.

We may also share your personal data with the below third parties:

• Our professional advisors such as our auditors and external legal and financial advisors;
• Marketing and communications agencies where they have agreed to process your personal data in line with this Privacy Notice;
• Business partners and sub-contractors.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws. Personal data may also be shared with third party service providers who will process it on behalf of InReach Group for the purposes above. Such third parties include, but are not limited to, providers of website hosting, maintenance, call centre operation and identity checking.

In the event that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.

4. How long will we keep your personal data?

We will not keep your personal information for any purpose for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose. We are also required to retain certain information as required by law or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

Where you are a customer, we will keep your information for the length of any contractual relationship you have with us. At the point where your contract comes to an end your information will be changed to that of a prospective customer. Where you are a prospective customer we will only retain your data until you unsubscribe from our communications.

In the case of any contact you may have with our call control team, your information will be retained as per our data retention policy.

We will retain your data for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place. In some instances, laws may require iNREACH Group to hold certain information for specific periods other than those listed above.

5. What are your rights in relation to your personal data?

You have the right to ask us not to process your personal data for marketing purposes. If you have previously agreed to us using your personal information for marketing, you may change your mind at any time by emailing enquiries@inreachgroup.co.uk or by clicking the unsubscribe button on any communication we have sent to you or by contacting us.

Where you have consented to us using your personal data, you can withdraw that consent at any time.

If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it.

You also have the right, to ask us to provide a copy of any personal data we hold about you.

Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format.

If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data.

a) By withdrawing your consent for us to use it;
b) If it is no longer necessary for us to use your personal data;
c) If you object to the use of your personal data and we don’t have a good reason to continue to use it; or
d) If we haven’t handled your personal data in accordance with our obligations.

6. Where can you find more information about iNREACH Group’s handling of your data?

Should you have any queries regarding this Privacy Policy, about iNREACH Group’s processing of your personal data or wish to exercise your rights you can contact iNREACH Group’s Data Protection Officer using this email address: enquiries@inreachgroup.co.uk. If you are not happy with our response, you can contact the Information Commissioner’s Office: https://ico.org.uk/

7. How we use Cookies

Cookies are small pieces of information stored on your computer used to identify you, including your IP address, operating system, and browser type. We may use cookies to track areas of the site that you have visited as well as to automate certain functions of the website and provide you with information about your account. iNREACH Group may use this information to contact you or your company from time to time about services that may be of interest or to process any application submitted by you in connection with a job vacancy (we may keep details of applications for the purpose of vetting future applications). If you wish your details to be removed from our information store, please contact us using this email address enquiries@inreachgroup.co.uk

8. Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

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