Privacy Policy

Welcome to Indigo Swan Limited’s privacy notice. Indigo Swan Limited shall be referred to as “Indigo Swan”, “we”, “us”, “our” throughout this privacy notice.

Indigo Swan respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are
   
2. The data we collect about you
   
3. How your personal data is collected
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Glossary
    

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Indigo Swan collects and processes your personal data through your use of this website, including any data you may provide through this website when you log-in to your client portal or make an enquiry.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Indigo Swan is the controller and responsible for your personal data.

We have appointed a data compliance manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data compliance manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity:  Indigo Swan Limited

Name of data compliance manager:  Andrew Kindleysides

Email address:  GDPR@indigoswan.co.uk

Postal address:  2 Millennium Plain, Norwich, NR2 1TF

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

You can find out more about our complaints handling process here

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 30/5/2018.

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.

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 notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you and we have grouped together the personal data that we may collect, use, store and transfer as follows:

• Identity Data includes your first name and last name
• Contact Data includes your address, e-mail address and telephone number.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Client Portal Data includes your email address and password, details of the services we are providing to you, and any feedback or survey responses.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not knowingly or actively collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we knowingly or actively collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you (for example, to provide the services you have requested), and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case we may not be able to perform the services, but we will notify you if this is the case at the time.

3. How your personal data is collected

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

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on this website, logging into the client portal, requesting for us to contact you or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• request for us to contact you;
• create and use the client portal on our website;
• request marketing to be sent to you, for example by signing up to receive our “Knowhow” updates;
• make an enquiry;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. 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 as set out as follows:
  Technical Data from the following parties:

• analytics providers;
• advertising networks; and
• search information providers.Contact, Financial and Transaction Data from providers of technical and payment services.
  Identity and Contact Data from data brokers or aggregators.
  Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4. How we use your personal data

We will only use your personal data 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 interests (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.

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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 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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Client Portal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You may receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside Indigo Swan for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages by contacting us at any time.

Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the services you have purchased, or any other transaction with us.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• External Third Parties as set out in the Glossary.
• 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 notice.

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.

6. International transfers

Some of our external third parties are based outside the European Economic Area (EEA) so we may be required to transfer your personal data outside the EEA from time to time.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. 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.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Details of retention periods for different aspects of your personal data are available on request by contacting us.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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. 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.

We use cookies on this website

A cookie is a text file sent by a web server to a web browser, and stored by the browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.

We may send a cookie which could be stored by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of this website, to improve the website’s usability and for marketing purposes.

We may also use that information to recognise your computer when you visit our website, and to personalise our website for you. Most browsers allow you to refuse to accept cookies.

(For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options” , “Privacy”, and selecting “Block all cookies” using the sliding selector.)

This will, however, have a negative impact upon the usability of many websites, including this one.

Cookie Policy

Indigo Swan use trusted third party cookies to give you the best possible experience on our website. When you visit the website, we will ask your consent to use the cookies.

Full explanations of these cookies are below in our cookie policy: Google Analytics Cookie (3rd Party) This allows Indigo Swan to see information on user website activities including, but not limited to page views, source and time spent on website.

The information is depersonalised and displayed as numbers, meaning it cannot be tracked back to individuals. This will help protect your privacy.

Google Analytics

Using Google Analytics we can see what pages you like reading and create more of the same for your enjoyment. Google analytic cookies are _utma, _utmb, _utmc and _utmz. Google Adwords (3rd Party)

Google Adwords

We also use Google Adwords coding so we can see what pages lead you to a contact form submission or lead form. This allows us to use our paid search budget more effectively and serve you the right adverts.

Tawk (live chat)

We use cookies as part of the chat service to enable us to track visitors on their journey through the website and to identify if they have visited the site previously.

The cookies are used solely for the purpose of personalising the experience for users of live chat. Users who remove cookies from their browser or who have not accepted them will not be treated as returning users or allow our operators to link any previous chats with the visitor. We don’t link the information we store in cookies to any other personal data that is submitted by the visitor while they are on the site.

DoubleClick (3rd Party)

Indigo Swan use remarketing codes to log when users view specific pages, allowing us to provide targeted advertising in the future. DoubleClick (3rd Party) Most browsers allow you to refuse to accept cookies.

(For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options” , “Privacy”, and selecting “Block all cookies” using the sliding selector.)

This will, however, have a negative impact upon the usability of many websites, including this one. Live Chat Cookies (3rd Party) Indigo Swan offers a live chat facility for real time customer service and use of this will place cookies on your device.

By consenting to use this site, we will assume you are OK with the use of cookies on our site however if you wish to find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.aboutcookies.org or www.allaboutcookies.org

Disclaimer

The information on this web-site has been compiled to the best of our knowledge from sources believed to be reliable. Whilst every effort has been made to ensure that the information is correct and that the views are sound, Indigo Swan cannot be made liable for any loss no matter how it may arise.

INTEGRATED MANAGEMENT SYSTEM POLICY 

Indigo Swan Limited has defined this IMS Policy and made it available to employees and other interested parties. The IMS Policy represents the framework for planning and improving the IMS and setting general and aspect-specific IMS objectives. The IMS Policy is appropriate to the Organisation’s processes, products and services; is derived from the overall corporate policies, context and strategy and provides a framework for establishing and reviewing overall strategic objectives.

The IMS Policy is approved by Senior Management and is displayed in the work/prominent areas of all working locations or otherwise effectively communicated to all staff and others affected by its activities. Periodically, Senior Management reviews the policy for its continuing suitability, adequacy and effectiveness and this is updated and re-issued as required. The IMS Policy includes a commitment to satisfy all applicable requirements and continual improvement of all aspects of the IMS.

Indigo Swan Limited is committed to:

• The satisfaction of our customers in all respects by supplying high-quality products and/or services, complying to relevant and agreed standards, on time and to defined criteria
• Fulfil our commitment through the involvement of all at Indigo Swan Limited and with continual improvement in our IMS
• Identify, prevent, control and minimise adverse impacts associated with our operational activities
• Comply with all applicable IMS requirements and compliance obligations
• The elimination of hazards and the reduction of OH&S risks
• The consultation and participation of employees and others working on its behalf and their representatives
• The protection of the environment, including the prevention of pollution
• Develop and maintain a highly motivated, trained, competent and aware workforce for effective management of IMS issues and requirements
• Communicate our IMS commitment to clients, employees and other interested parties
• Strive to continually improve our IMS performance keeping in view regulatory requirements, Health & Safety requirements, environmental requirements, community concerns and technological advancements
• Establish and maintain a suitable, safe and healthy work environment
• Comply with all applicable legal requirements
• Adopt the best practice of operations to prevent adverse consequences.

Modern Slavery and Human Trafficking Statement

We are not required to formally produce a Modern Slavery and Human Trafficking Statement, however we make a voluntary commitment. Indigo Swan is committed to the principles of the Modern Slavery Act and the abolition of modern slavery and human trafficking. As an equal opportunities employer, Indigo Swan is committed to creating and ensuring a non-discriminatory and respectful working environment for its staff.

Indigo Swan’s recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion once in our employment.

Our team are aware of the Modern Slavery Act and we have informed them of the appropriate action to take if they suspect a case of slavery or human trafficking.