Introduction
We respect your privacy and are committed to protecting your personal data. This privacy policy will explain how we collect, process and look after your personal data when you visit the isme|&|co website (regardless of where you visit it from), and tell you about your privacy rights and how the law protects you. It will also provide you with information about the cookies we use on our website.

When we refer to “isme|&|co”, we mean PaaS Genesis Limited, the entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.

Our website is designed and intended for business use. As such is not intended for children, and we do not knowingly collect data related to children.

Data Protection
As a general rule, it is possible to use our website without entering your personal data. However, the website is designed to offer greater utility and value to users who do enter certain personal data. In so far as personal data (e.g. name, address or e-mail addresses) are collected on our pages, then this is always done as far as possible on a voluntary basis. Should you provide such data, it will not be sold to third parties for marketing purposes without your explicit agreement.

Our 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 policy of every website you visit. For example, Google. A copy of Google’s Privacy and Terms can be found here.

We’d also like to draw your attention to the fact that the transmission of data on the internet (e.g. in the course of communication via e-mail) can be subject to security vulnerabilities. Absolute protection of data from access by third parties is not possible. However, we do take the privacy of your personal data very seriously and endeavour to take all reasonable commercial efforts to protect it.

Our Commitment to Privacy
Your privacy is important to us. To better protect you, we provide this Policy explaining our online information practices and the choices you can make about the way your information is collected and processed.

Please read this Policy carefully as it describes our collection, use, disclosure, retention and protection of your personal information. This Policy applies to our website https://www.ismeandco.com (the “Site”), also referred to as the isme & co platform (the “Platform”). If you do not agree with the terms, please do not access the Platform or any other aspect of isme|&|co business.

By using the Platform or any of our services you consent to the privacy practices described in this Policy.

This Privacy Policy does not apply to any third party applications or software that integrate with the isme|&|co platform (“Third Party Services”), or any other third party products, services or businesses. In addition, a separate agreement governs access to and use of the isme|&\co platform (the “Terms of Service”), including the processing of any data or other content associated with Subscriber accounts (collectively, “Subscriber Data”).

isme|&|co reserves the right to change this Policy without notice at any time. If we make any changes to our Policy, we will post a new policy on our Site and update the “last updated” date shown above. The updated Policy will be effective immediately and will govern each use of the Site from the date of update onwards. Therefore, we recommend that you check the Policy regularly, prior to using the Site.

How We Collect Information
To the extent permissible under applicable law, we collect information about you (hereinafter referred to as “Subscriber Information”) when you:
• direct interactions, such as signing up to create an account in order to use certain aspects of our Platform or services; this may include your name (including business name), address, email address, IP address and telephone number. We may also ask you to provide additional information about your business and your preferences;
• place an order (including subscribing for membership) using our Platform or services; this may include your name (including business name), address, contact (including telephone number and email address), IP address and payment details;
• complete online forms (including call back requests), take part in surveys, post on our message boards, post any blogs, download information such as white papers or other publications or participate in any other interactive areas that appear on our Platform;
• interact with us using social media;
• contact us offline, for example by telephone, fax, SMS, email or post;
• automated technologies or interactions, when you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy below for further details.
• third parties or publicly available sources. We will receive personal data about you from various third parties as set out below.

Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks based inside or outside the EU; and
(c) search information providers based inside or outside the EU.

We will also collect your information where you only partially complete and/or abandon any information inputted into our Platform and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.

If you intend giving us personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protections laws. In so far as required by applicable data protection laws, you must ensure that beforehand you have their explicit consent to do so and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Policy.

The Personal 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, which we have grouped together as follows:
• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• 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.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

We do not 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 collect any information about criminal convictions and offences.

How We Use Your Personal Data
Where you provide us with your personal data in any of the ways described in this Policy, you agree that we may collect, store and use it:
(a) in order to perform our contractual obligations to you;
(b) where necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests;
(c) based on your consent, which you may withdraw at any time, as described in this Privacy Policy; or
(d) where we need to comply with a legal obligation.

For the purposes of this Policy:

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.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product, 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.

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

Purposes for which we will use your Personal Data
We have set out below, a description of all the ways we plan to use your personal data. 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.

isme|&|co uses Subscriber Information in the furtherance of our Legitimate Interests in operating our Platform and business. More specifically, to the extent permissible under applicable law, we use your information to:
• provide any information and services that you have requested or any applications or services that you have ordered;
• provide, maintain, protect and improve any applications, products, services and information that you have requested from us;
• manage and administer your use of applications, products and services you have asked us to provide;
• manage our relationship with you (for example, customer services and support activities);
• monitor, measure, improve and protect our content, website, applications and services and provide an enhanced, personal, user experience for you;
• provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
• detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
• contact you to see if you would like to take part in our customer research (for example, feedback on your use of our applications, products and services);
• to monitor, carry out statistical analysis and benchmarking, provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual;
• deliver targeted advertising, marketing or information to you which may be useful to you, based on your use of our website and services;
• deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers); and
• provide you with location-based services (for example, advertising and other personalised content), where we collect geo-location data.

To the extent permitted by applicable law, we retain information about you after the closure of your isme|&|co account, if your application for an isme|&|co account is declined or if you decide not to proceed. This information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.

Our Platform and services may contain technology that enables us to:
• check specific information from your device or systems directly relevant to your use of the Platform or services against our records to make sure the Platform or services are being used in accordance with our end-user agreements and to troubleshoot any problems;
• obtain information relating to any technical errors or other issues with our Platform and services;
• collect information about how you use the functions of the features of our Platform, applications and services; and
• gather statistical information about the operating system and environment from which you access our Platform, applications or services.
You can manage your privacy settings within your browser.

In addition to the purposes described in this section, we may also use information we gather to deliver targeted advertising, marketing or information to you which may be useful, based on your use of the Platform or services, or any other information we have about you.

We may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our Platform and services you order from us or ask us about, and in order to meet our legal and regulatory obligations generally.

Data Retention
We will retain your personal data in accordance with your instructions, including any applicable terms in the Terms of Service and your use of our services functionality, and as required by applicable law. The deletion of your personal data and other use of our services by you may result in the deletion and/or de-identification of certain associated Other Information.

isme|&|co may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for isme|&|co to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

Sharing Your Information
We will never sell your personal information to third parties. We may, however, share your information with:
• our service providers and agents (including their sub-contractors) or third parties which process information on our behalf (e.g. internet service and platform providers, payment processing providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the applications, products, services and information you have requested or which we believe is of interest to you;
• partners, including system implementers, resellers, value-added resellers, independent software vendors and developers that may help us to provide you with the applications, products, services and information you have requested or which we believe is of interest to you;
• third parties used to facilitate payment transactions, for example clearing houses, clearing systems, financial institutions and transaction beneficiaries;
• third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites or other third party application providers);
• regulators to meet isme|&|co’s legal and regulatory obligations;
• law enforcement agencies so that they may detect or prevent crime or prosecute offenders;
• any third party in the context of actual or threatened legal proceedings, provided we do so lawfully (for example in response to a court order);
• any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
• our professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
• another organisation if we sell or buy (or negotiate to sell or buy) any business or assets;
• another organisation to whom we may transfer our agreement with you; and
• Government departments where reporting is mandatory under applicable law.

We may share non-personally identifiable information about the use of our Platform, applications, products or services publicly or with third parties but this will not include information that can be used to identify you.

We will use commercially reasonable endeavours to ensure the confidentiality of your personal information. However, we cannot guarantee that your personal information will not be disclosed to third parties. For example, we may be legally obligated to disclose information to the government or third parties under certain circumstances, or third parties may circumvent our security measures to unlawfully intercept or access transmissions or private communications.

Our Commitment to Data Security
In order to prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

Each user account holder, whether a subscriber to services or not, is asked to create a unique password, which is required to access their account. It is each user’s responsibility to protect the security of his or her login information.

These safeguards help prevent unauthorised access, maintain data accuracy, and ensure the appropriate use of data, but no guarantee can be made that your information and data will be secure from intrusions and unauthorised release to third parties.

If you believe your account has been compromised, please contact us at support@ismeandco.com

Marketing
From time to time, we may use your information to contact you by email with details about our applications, products and services which we feel may be of interest to you. You have the right at any time to stop us from contacting you for marketing purposes. If you wish to exercise these rights you can do so by sending us an email to support@ismeandco.com. You can also unsubscribe from any email marketing using the links provided in the emails we send to you.

Your information and your rights
If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:
• the right to be told how we use your information and obtain access to your information;
• the right to have your information rectified or erased or place restrictions on processing your information;
• the right to object to the processing of your information e.g. for direct marketing purposes;
• the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
• where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
• the right to object to any decisions based on the automated processing of your personal data, including profiling; and
• the right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in the UK, the Information Commissioner’s Office).

If you request a copy of your information you may be required to pay a statutory fee.

If we hold any information about you which is incorrect or if there are any changes to your details, please let us know so that we can keep our records accurate and up to date.

Please note, if you do withdraw your consent to the use of your personal information for purposes set out in our Privacy Policy, we may not be able to provide you with access to all or parts of our website and services.

We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, or as otherwise permitted by law. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).

Transfers outside of the European Economic Area
Personal information in the European Union is protected by data protection laws but other countries do not necessarily protect your personal information in the same way.

Our Platform and some of our services or parts of them may also be hosted in the United States or otherwise outside of the EEA (which means all the EU countries plus Norway, Iceland and Liechtenstein) (“EEA”) and this means that we may transfer any information which is submitted by you (through the Site or offline) outside the EEA to the United States or to other territories outside of the EEA. When you send an email to us, this will also be stored on our email servers which may be hosted outside of the EEA.

We may use service providers based outside of the EEA to help us provide our Platform and services to you (for example, platform and payment providers who help us deliver our applications and services, or advertising or execute your payments) and this means that we may transfer your information to service providers outside the EEA for the purpose of providing our applications, advertising and services to you.

We take steps to ensure that where your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures and controls are in place to protect that information in accordance with applicable data protection laws and regulations. In each case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.

By using our Platform or services or by interacting with us in the ways described in this Privacy Policy, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Policy. If you do not want your information to be transferred outside the EEA you should not use our Platform, applications or services.

Cookies, Analytics and Traffic Data
Cookies are small text files which are transferred from our websites or services and stored on your device, if you agree.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Platform may become inaccessible or not function properly.

Our Platform uses cookies to distinguish you from other users of our Platform. This helps us to provide you with a good experience when you browse our Platform and also allows us to improve our Platform.

By continuing to browse the Platform, you are agreeing to our use of cookies.

Our cookies may be session cookies (temporary cookies that identify and track users within our websites, applications or services which are deleted when you close your browser or leave your session in the Platform or service) or persistent cookies (cookies which enable our Platform, applications or services to “remember” who you are and to remember your preferences within our Platform, applications or services and which will stay on your computer or device after you close your browser or leave your session in the application or service).

We use the following different types of cookies:

Strictly necessary cookies
These are cookies which are needed for our Platform or services to function properly, for example, these cookies allow you to access secure areas of our Platform and to remember you.

Performance cookies and analytics technologies
These cookies collect information about how visitors and users use our Platform and services, for instance which functionality visitors use most often, and if they get error messages from areas of the Platform or services. These cookies don’t collect information that identifies a visitor or user. All information these cookies collect is aggregated and therefore anonymous. We only use these cookies to improve how our Platform, applications and services work.

Functionality cookies
These cookies allow our Platform, applications and services to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. They may also be used to provide services you have asked for. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Web beacons and parameter tracking
We also use cookies and similar software known as web beacons to count users who have visited our Platform after clicking through from one of our advertisements on another website or in emails and to collect details of any services purchased. These web beacons collect limited information which does not identify particular individuals. It is not possible to refuse the use of web beacons. However, because they are used in conjunction with cookies, you can effectively disable them by setting your browser to restrict or block cookies.

IP Address and traffic data
We keep a record of traffic data which is logged automatically by our servers, such as your Internet Protocol (IP) address, device information, the website that you visited before ours and the website you visit after leaving our Platform. We also collect some site, application and service statistics such as access rates, page hits and page views. We are not able to identify any individual from traffic data or site statistics.

You can find more information about the individual cookies we use, the purposes for which we use them, and their expiration in the tables below:

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.

Our Commitment to Children’s Privacy
Protecting the privacy of the very young is especially important to us. For that reason, we never collect or maintain information at our Platform from those we actually know are under the age of 16, and no part of our Platform is structured to attract anyone under 16.

Other websites
Our Platform contains links to other websites. Please note that when you click on one of these links, you are entering another website over which isme|&|co has no control and will bear no responsibility. We encourage you to read the privacy statements on all such websites as their policies may be different to ours.

Identifying The Data Controller And Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, a Subscriber is the controller of Subscriber Data. In general, isme|&|co is the processor of Member Data and the controller of Other Information.

Your Rights
To the extent that isme|&|co’s processing of your Personal Data is subject to the General Data Protection Regulation, isme|&|co relies on its Legitimate Interests, described above, to process your data. isme|&|co may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to isme|&|co’s use of your Personal Data for this purpose at any time.

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information.

Under normal circumstances you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Data Protection Authority
Subject to applicable law, you also have the right to (i) restrict the use by isme|&|co of Other Information that constitutes your Personal Data and (ii) lodge a complaint with the Information Commissioner’s Office in the UK, which is the relevant lead supervisory authority. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate number)
Fax: 01625 524 510

Contacting isme & co
Please also feel free to contact isme|&|co if you have any questions about this Privacy Policy or the practices of isme|&|co, or if you are seeking to exercise any of your statutory rights. You may contact us at support@ismeandco.com or at our mailing address below:

isme|&|co
c/o PaaS Genesis Limited
High Lane House
148 Buxton Road
High Lane
Stockport
SK6 8ED.

All trademarks acknowledged.