Privacy Policy 

Introduction

This is the privacy notice for the Iris Worldwide group of companies.

Iris Worldwide respects your privacy and is committed to protecting your personal data.

1. Important information and who we are

Purpose of this privacy notice

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), use our services, or register to attend our events (“Services”). We are committed to protecting your personal data and this privacy notice will explain how we look after it, what rights you have, as well as how the law protects you. To the extent not specifically set forth in our Services, our website is not intended for children and we do not knowingly collect data relating to children.

The Iris Worldwide group is made up of different legal entities and this privacy notice is issued on behalf of the Iris Worldwide group so when we mention "Iris", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Iris Worldwide group responsible for processing your data. Iris Nation Worldwide Limited is the controller and responsible for this privacy notice.

We have appointed a data protection officer (DPO) 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 DPO using the details set out below.

This privacy notice should be read together with any other provided privacy notice or fair processing notice we may provide on specific occasions when we are collecting or otherwise processing personal data about you so that you know how and why we are using it. This privacy notice supplements those other notices and is not intended to override them. Contact details

Our full details are:

Full name of legal entity: Iris Nation Worldwide Limited

Data Protection Officer’s email address: dpo@iris-worldwide.com

Postal address: 3rd Floor, 10 Queen Street Place, EC4R 1BE

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

This version was last updated on 21 July 2022.

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.

How this privacy notice operates with our other privacy notices

It is important that you read this privacy notice together with any other privacy notices that we may provide on specific occasions when we are collecting or otherwise processing personal data about you and for our Services so that you know how and why we are using it. This privacy statement supplements those other notices and is not intended to override them.

2. The data we collect about you

Personal data, or personal information, means any information about a living 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 follows:

• Identity Dataincludes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender
• Contact Dataincludes billing address, delivery address, email address and telephone numbers
• Financial Dataincludes bank account and payment method details
• Transaction Dataincludes details about payments to and from you and other details of services you have purchased from us
• Technical Dataincludes 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, together with CCTV and other visual or audio recordings, including photographs
• Profile Data includes your interests, attendance at our events, preferences, feedback and survey responses – which may include Special Categories of Personal Data
• Usage Dataincludes 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 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.

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, 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 (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

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

• Direct interactions.You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • make enquiries of, and/or seek to procure our, services
  • apply for a job with Iris
  • contact us via one of the communication means set out on our website
  • enter into an agreement with us for the provision of, or receipt of, services
  • request marketing and other promotional material to be sent to you
  • enter a survey
  • 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.
• Third parties or publicly available sources.We may receive personal data about you from our clients, various third parties and public sources.

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 we need to carry out our obligations arising from any agreements between our clients and us (which will usually be for the provision of our Services, where you may be a sub-contractor, supplier or customer of our client)
• 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
• Where you have consented to its use

Purposes for which we will use your personal data

We may use your personal data to:

• Carry out our obligations arising from any agreements between our clients and us (which will usually be for the provision of our Services, where you may be a sub-contractor, supplier or customer of our client)
• Provide you with information related to our Services and our events and activities that you request from us or which we feel may interest you, providing you have consented to be contacted for such purposes
• Seek your thoughts on the services we provide
• To process and consider your job application, where we use our legitimate interests to process your personal data for assessing your job application and to keep you updated throughout the application process

Marketing information from us

We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile 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 (we call this marketing).

You will 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. This is in line with our legitimate interest.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Iris Worldwide group of companies for marketing purposes.

Opting out

We try to always include an opt out option of any marketing messages. Where this is not possible, you can ask us to stop sending you marketing messages at any time by contacting us

Where you opt out of receiving these marketing messages, this will not mean you receive no messages at all from us – we may still need to use your personal data provided to us to contact you as a result of a service purchase, service experience or other transactions.

Cookies

For more information about the cookies we use, please see our cookies policy

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 other organisations from time to time, but we will maintain responsibility for what they do with your data and how it is processed. 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 providers to use your personal data for their own purposes and we only permit them to access your personal data for specified purposes and in accordance with our instructions – for example, service providers who process data for us, including those providing IT and system administration services and hosting.

6. International transfers

Generally, we process your personal data within the UK and/or European Economic Area (EEA). If we need to transfer your personal data out of the UK and/or EEA, we will ensure an equivalent level of protection is afforded to it as if it were being processed within the UK and/or EEA. We will only process your personal data outside of the UK and EEA:

• if the transfer of your personal data is to a country that has been deemed to provide an adequate level of protection for personal data by the United Kingdom Government or the European Commission
• if we have entered into with the recipient of the personal data located outside of the UK or EEA one of the specific contracts approved by the European Commission or the United Kingdom Government which give personal data the same protection as it has in the EU or UK respectively, and have carried out an appropriate assessment of that relevant country’s data protection laws and, if necessary, implemented additional safeguards and/or supplementary measures to ensure an adequate level of protection applies.

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 also 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.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

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 accessto your personal data (also known as a “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 correctionof the personal data we hold about you. This allows you to have any incomplete or inaccurate data we hold about you corrected
• Request erasureof your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue 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, where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with the law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which, if applicable, we will notify you
• Object to processingof your personal data where we are relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to our processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes
• Request restriction of processingof your personal data. This enables you to ask us to suspend the processing of your personal data in any of 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 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 transferof your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly-used and 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 timewhere 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 services to you. We will notify you if this is the case

If you want to exercise any of these rights, please contact us.

Should you wish to access your data, please note the following:

• you will not normally 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 (or we may 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 respond to all legitimate requests as quickly as possibly, and in any case within one month unless:

• your request is particularly complex or you have made a number of requests;
• we require more information from you;
• we require a payment from you that we are entitled to request,
• your delay in providing the information or payment to us; or
• your request is clearly unfounded, repetitive or excessive but we have agreed to reply to it anyway.
• In any of these cases, we will notify you and keep you updated of the expected time of our reply

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.

10. Your California Privacy Rights

The following section pertains to the rights of individuals or households in California (“California consumers”). 

• Civil Code Section 1798.83

Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California consumer, a business may be required to provide detailed information regarding how that business has shared that customer’s personal data with third parties for direct marking purposes. However, the foregoing does not apply to businesses like ours that do not disclose personal data to third parties for direct marketing purposes without prior approval or give customers a free mechanism to opt out of having their personal data disclosed to third parties for direct marketing purposes.

• Rights under the CCPA

The California Consumer Privacy Act (“CCPA”) (California Civil Code Section 1798.100 et seq.) provides California consumers with additional rights regarding “Personal Information” which is defined as personal data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household. The categories of Personal Information we collect are generally described above in Section 2 but differ for individual consumers depending on the services used by such consumers.

Under the CCPA, qualifying California consumers may have the following rights:

Right to Know and Right to Delete.

A California consumer has the right to request that we disclose what Personal Information we collect, use, disclose and sell. A California consumer also has the right to submit requests to delete Personal Information.

When we receive a request to know or delete from a California consumer, we will confirm receipt of the request within 10 days and provide information about how we will process the request, including our verification process. We will respond to such requests within 45 days.

Right for Disclosure of Information.

A California consumer may also submit requests that we disclose specific types or categories of Personal Information that we collect.

Under certain circumstances, we will not provide such information, including where the disclosure creates a substantial, articulable and unreasonable risk to the security of that Personal Information, customers’ account with us, or the security of our systems or networks. We also will not disclose California consumers’ social security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medical identification numbers, or account passwords and security questions and answers.

Submitting Requests

If you are a California consumer and would like to make any requests under the CCPA, please direct them as follows dpo@iris-worldwide.com or to Iris Worldwide, 3^rd Floor, 10 Queen Street Place, London EC4R 1BE, United Kingdom.

Verifying Requests

If we receive any requests we will use a two-step process for online requests where the California consumer must first, clearly submit the request and then second, separately confirm the request. We will use other appropriate measures to verify requests received by mail or telephone.

In submitting a request, a California consumer must provide sufficient information to identify the consumer, such as name, e-mail address, home or work address, or other such information that is on record with us so that we can match such information to the Personal Information that we maintain. Do not provide social security numbers, driver’s license numbers, account numbers, credit or debit card numbers, medical information or health information with requests. If requests are unclear or submitted through means other than outlined above, we will provide the California consumer with specific directions on how to submit the request or remedy any deficiencies. If we cannot verify the identity of the requestor, we may deny the request.

• California Do Not Track Disclosures

Although some browsers currently offer a “do not track (‘DNT’) option,” no common industry standard for DNT exists. We therefore do not currently commit to responding to browsers’ DNT signals.