Our Privacy Policy

Published: January 2020

Introvice Ltd is a company registered in England and Wales, registration number 10854063, whose registered office is situated at 260-264 Charminster Road, Bournemouth, BH8 9RR.  We design and provide lead tracking and business management solutions to facilitate end user introductions to financial services companies.

Our Privacy Policy

We respect your right to privacy and take our responsibilities very seriously in relation to the processing of personal data.  We do not collect or process data unnecessarily.  This policy sets out important information about your rights in relation to the processing of your personal data, in additional to the measures we will take to keep your personal data secure.

Data controller and contact Details

For the purposes of relevant data protection legislation, we are the processor of the personal data and our contact details are as follows;

  • Email: privacy@introvice.co.uk
  • Telephone: 01202 390050
  • Address: 260-264 Charminster Road, Bournemouth, BH8 9RR

Information we collect and how do we collect It

Introvice client data (Our Customer)

This is information that will be given to us either as part of the on-boarding process or will be entered into the platform during the period of the subscription.
This Information may include;

  • ID Data: Full Name, Email Address

Introducer data

This is information that will either be added by the Introvice Client or an Introducer with the appropriate role
This information may include;

  • ID Data: Full Name, Email Address, Mobile Telephone Number
  • Financial Data: Bank Name, Sort Code, Account Number

Your end customer data

Whilst using this service you may input or store the personal data of your leads, clients, suppliers or other parties, which may include details such as names, email address, contact numbers and financial details which may be used in relation to providing financial services products. As we have no direct relationship with the individuals whose personal data we host, you are responsible for providing notice to these parties concerning the purpose for which you collect their personal data and how you intend to process it. You are also responsible for ensuring you have duly received their consent for said storage and processing as well as ensuring the completeness and accuracy of their personal data.

Automatically collected data

Whilst using our website (www.introvice.co.uk), our client portal (portal.introvice.co.uk) or our business tracking portal (businesstracking.co.uk) we will automatically collect the following;

Technical Data: Including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.

Usage Data: information about your visit, including the URL, clickstream to, through and from our site (including date and time), page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).

Special categories of personal data

We do not require or collect any personal data that is your sensitive personal data or any special category of personal data under the GDPR, unless you decide to provide this information to us.

Cookies

Our sites utilise cookies. More information can be found in our Cookie Policy
What we do with your information
We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

We have provided a summary table below of the ways we plan to use your personal data and the legal basis we rely on to do so.

Access to your information

We do not pass on or sell your data for marketing or other purposes. We do not share information without consent unless the law and this policy allow us to do so.

The following persons will have access to your data

  • Any authorised employee if Introvice Ltd.
  • Selected third parties including;
    • SendGrid – For the purposes of sending emails from the platform for operational purposes. E.g. Case Updates, Password resets, etc
    • Eazipay Ltd – For the purposes of setting up and processing Direct Debit Instructions
    •  Analytics and search engine provides that help us monitor and improve the performance of the site such as Google Analytics.

We will disclose your personal information to third-party recipients.

If we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of our business or assets.

  • If Introvice is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any law, legal obligation or court order, or in order to enforce rights under the GDPR or to apply our Terms of Service and other agreements.
  • To protect our rights, property or safety, our customers, or others. This includes exchanging information with other companies and organizations for the maintenance and security of the Site and Services.

How we protect your data

We take our role in protecting personal information seriously, however transmission of information across the internet can never be completely secure. Although we will always do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; 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.

Service location and data storage

Our services are hosted in Microsoft Azure Datacentres which are in the United Kingdom. We will not transfer personal data outside the EU unless specified elsewhere in this privacy policy.
Our services are only access via HTTPS (SSL) which helps ensure communication between you and our applications are secure and private.

Data Backup

Your personal data as well as your end customer data is backed up daily. Please refer to this link regarding security and privacy in Microsoft Azure.
https://azure.microsoft.com/en-gb/support/legal/

Data Encryption

Data is encrypted using SSL certificates whilst transferring between you and our service. In addition, encryption is enabled on the underlying database layers.

Access Restriction

Access to production systems is tightly controlled and is only available to authorised Introvice employees.

Your Rights

Accessing your personal data

You may request access at any time to a copy of the personal data we hold about you. Any such request should be submitted to us in writing and sent to privacy@introvice.co.uk. We will need to verify your identity in such circumstances and may request more information or clarifications from you if needed to help us locate and provide you with the personal data requested. There is usually no charge applied to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.

Restriction

You may restrict us from processing your personal data in any of the following circumstances:

  • You have contested the accuracy of the personal data we hold on record in relation to you or for a period of time to enable us to verify the accuracy of the personal data;
  • The processing of your personal data is unlawful and you request the restriction of the use of personal data instead of its erasure;
  • We no longer require your personal data for the purpose of processing but you require this data for the establishment, exercise or defence of legal claims; or
  • Where you have contested the processing (under Article 21(1) of the GDPR) pending the verification of our legitimate grounds.

Right to Rectification and Right to Be Forgotten

If we hold personal data concerning you which are no longer necessary for the purposes for which they were collected or if you withdraw consent for us to process your personal data, you can request the deletion of this personal data. This right, however, will not apply where we are required to process personal data in order to comply with a legal obligation or where the processing of this information is carried out for reasons of public interest in the area of public health. If the personal information we hold about you is inaccurate, you may request to have your personal information updated and corrected. To do so at any time, please contact us by email at privacy@introvice.co.uk

Right to Object

  • For direct marketing purposes
  • For profiling to the extent it relates to direct marketing
  • Where we process your personal data for the purposes of legitimate interests pursued by us, except where we can demonstrate compelling legitimate grounds for this processing which would override your interests, rights, and freedoms or in connection with the enforcement or defence of a legal claim

To exercise your right to object at any time, please email privacy@introvice.co.uk. Should this occur, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above

Personal Rights

The rights described in this section are personal rights and are exercised only by the individual person (or data subject) concerned. If we receive any such request or communication directly from your customers and/or in relation to your end customer data, we will refer the matter to you and cooperate in providing such reasonable assistance as may be required to enable you, as a controller, to respond to the matter.

Change to our policy

Any changes made to this Policy from time to time will be published at the Site.
Any material or other change to the data processing operations described in this Policy which is relevant to or impacts on you or your personal data will be notified to you in advance by email. In this way, you will have an opportunity to consider the nature and impact of the change and exercise your rights under the GDPR in relation to that change (e.g., to withdraw consent or to object to the processing) as you see fit.

Questions or Complaints

If you have any question or complaints, please direct them to us in the first instance.

If you believe we have not complied with our obligations, then you of course have the right to contact the office of the Data Protection Commissioner.

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