ingage IR Limited is a limited company registered in England and Wales under company number 8633711 whose registered office is at The Broadgate Tower, Third Floor, 20 Primrose Street, London EC2A 2RS, United Kingdom (hereinafter referred as “ingage”, “us” or “we”).
You must read this policy before using our websites (including those available via the URLs www.ingage.com and www.ingageir.com), our mobile app or any other URL on which we make any of our websites available (the “Website”). By accessing, browsing or otherwise using the Website, you are deemed to have read, understood and agreed to this policy. If you do not agree with any part of this policy, you must not use the Website.
For the purposes of applicable data protection laws, ingage is a ‘controller’ of certain personal data that is processed through the Website. We are committed to respecting the privacy of individuals whose personal data we process. This includes information about you that we collect directly from you, or through third parties.
We have appointed a Data Protection Officer to oversee any questions or issues in relation to this policy. If you have any questions or wish to exercise any of your legal rights in relation to your personal data, please contact the Data Protection Officer using the details set out below:
Email: firstname.lastname@example.org (please use “Data Protection Officer” in the email subject line)
Tel: +44 (0) 20 7118 2288
Address: Data Protection Officer, The Broadgate Tower, Third Floor, 20 Primrose Street, London EC2A 2RS, United Kingdom
Collection and Use of Personal Data
When you register to use the Website
If you register to use the Website, we will collect certain personal data about you, including your name, date of birth, gender, telephone number(s), email address(es), title, position and job details.
When you contact us
If you contact us by telephone, email, post or using any function made available on our Website, we will collect any personal data about you that you choose to give us.
When you use interactive features of the Website
We may make interactive features available on our website including, for example, questionnaires or surveys (see “Survey Contributions” section below for more information). If you choose to use these features, we will collect any information and personal data that you choose to give us. We will use this information to review and improve our services (the “Services”).
Information we may collect about you from third parties
The Website makes available, to both our corporate customers and investor customers, a database of contacts. To compile this database and keep it up to date, we obtain certain information, which may include your personal data, under licence from third party data suppliers such as FactSet Research Systems, Inc. and from other users of the Website. The information we receive includes identity and contact data such as name, telephone numbers, email addresses, title, position and job details. We may also obtain information from your employer’s website, and from your public profile on LinkedIn.
IP Addresses, Cookies and Web Logs
As with most websites, our servers automatically collect certain technical information such as your IP address, the date and time of your visit, and information about the browser you use. This information is used for system administration and to collect and report aggregate information on visits to the Website and users’ browsing patterns which does not identify specific individuals.
Like many other companies, we also use ‘cookie’ technology, where our servers deposit special codes on a visitor's computer. Cookies help us to improve the Website and to deliver a better and more personalised service. As above, this information also helps us determine the total number of visitors to the Website and browsing patterns on an on-going basis and the types of Internet browsers (e.g., browsers from Google, Apple, Microsoft and Mozilla) and operating systems (e.g., Microsoft Windows, Android or Apple iOS) used by our visitors. This information is used to improve the Website and enhance your online visits. We do not use this information to identify visitors or cross-reference this information with personal data you may provide on the Website. If you wish, you can set up your browser so that you do not receive any 'cookies' while visiting the Website, but if you do so this may affect the performance of the Website and you may not be able to use all the options otherwise available.
For more information on how we use and manage cookies, please see our Cookies Policy.
How Your Personal Data Will Be Used
We use the information held about you to provide you and others with the services offered by means of the Website, to ensure that content from the Website is presented in the most effective manner for you and for your computer, or device, and to notify you about any changes to our Services. We may also track what online content you are interested in or use aggregate user information to assess general user interest in various products and services. We do this to focus our communications and provide you content and services we believe may be of interest to you. We also use the information you provide to ensure compliance with this policy.
In summary, we use your personal data for the following main purposes, to:
- provide, manage and improve the Website and our Services;
- personalise our service to you;
- administer and operate your account;
- process your requests, for example to reserve a spot at a meeting which you choose to attend;
- help you in targeting investors / corporates you may wish to engage or meet with;
- provide feedback provided by you or in relation to you as part of the Services;
- provide you with information, products or services that you request from us or which we feel may interest you (where you have consented to be contacted for such purposes);
- provide user support, process any complaints or enquiries made by you and to tell you about important changes to the Services and the Website;
- provide reports to our content suppliers;
- provide reports, analytics and benchmarking to you and other users of the Website and our Services;
- to contact you (including by email, SMS and push notifications) about our products, Services, service updates and alerts, offers which we think may be of interest to you and for market research purposes, subject always to your marketing preferences;
- to maintain a register of members of the investment and Investor Relations community (the “Contact Manager”), and to allow our clients to send communications to you;
- for research, analysis and risk management;
- conduct marketing or research; and
- to perform and enforce our Supply Terms and Conditions or other agreements in relation to the Services.
Recipients of Personal Data
If your details appear in the Contact Manager section of the Website, they will be viewable by other users of the Website. We will also disclose personal data we hold about you to:
- our service providers, including IT hosting companies;
- third parties in the event that we sell, or explore the sale of, any relevant part of our business or related assets to that third party;
- professional advisors, such as attorneys/lawyers, accountants, auditors, financial and other professionals;
- regulatory authorities, law enforcement agencies, courts and other relevant tribunals if we are under a duty to disclose or share any data by applicable law, to comply with any legal obligation or are permitted to do so to enforce any term of this policy or our Supply Terms and Conditions or other agreements in relation to the Services.
Service providers that we engage will only be permitted to use personal data where necessary for the services being provided by them and will not be permitted to use such personal data for any other purpose. We will require service providers to process the personal data on terms no less stringent than this policy and ask them to adhere to all applicable laws.
Except as described above and in the section below (Survey Contributions), we will not share, exchange, sell or rent your personal data with any other third parties without your permission.
Our Legal Basis for Processing your Personal Data
You may be requested by us to complete a survey or feedback issued either by ingage or commissioned by one of our subscribers (a “Survey”).
You are under no obligation to accept the invitation to respond to a Survey and your response is voluntary. If you decide to respond to the Survey, the lawful basis on which we process your personal data is that it is necessary for our legitimate interests in running our business, as described above. You acknowledge that:
(a) your responses to the Survey, including your name and contact details (the “Survey Responses”) will be shared with the relevant commissioning subscriber, who will handle your information in accordance with their own privacy policies, over which we have no control. We will ask them to only use the Survey Responses for their own internal business purposes;
(b) we will use your Survey Responses for our own business purposes, including to publish our own reports and analysis of the feedback provided. We will only publish such information in a form that does not identify you.
Your personal details (name and contact details) will only be disclosed to the subscribers to whom the Survey relates or those commissioning the Survey. We confirm that if we use your Survey Responses in any other public format, your anonymity will be preserved.
Storage and Security
Where we have provided you (or where you have chosen) a password that enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Please remain guarded against phishing emails. Phishing is a method used by fraudsters to deceive someone into giving sensitive information, such as bank account details, credit card numbers or username and passwords. Most of the time, phishing will take the form of emails, which purport to be from well-known companies and ask recipients to send their private information. This information is then used for identity theft and fraud. We will never ask you for your account password. If you have any suspicions or doubts whether any email or communication that purports to come from us is genuine or not, please check with us first
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.
You have certain rights in relation to your personal data under data protection laws. You have the right to request: (i) access to your personal data; (ii) the transfer of your personal data to another controller (portability); (iii) the rectification (update or correction) of your personal data if it is incomplete or inaccurate; (iv) erasure of your personal data (the right to be forgotten); (v) restriction of processing of your personal data; (vi) your personal data is not processed (object to the processing of your personal data). These rights are not absolute. Where we have obtained your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
You have the right to ask us at any time not to use your personal data for direct marketing purposes. You can exercise this right at any time by contacting us or by choosing the “unsubscribe” option in marketing emails you receive from us.
If you would like to exercise any of these rights, or if you have any other queries about this policy, please contact the Data Protection Officer (see contact details above). There may be a reasonable charge to exercise some of your rights where permissible under applicable law. We will respond to all legitimate requests within one month. Occasionally it may take us longer than a month if we need additional information to verify your identity, your request is particularly complex or you have made a number of requests. In these situations, we will notify you and keep you updated.
Processing for our Subscribers and Clients
Our Website enables our clients to access certain functions, such as to schedule and manage meetings, send out communications to the investment and Investor Relations community, create itineraries, record notes, provide and collect feedback. Where ingage acts as host and manages data on behalf of our clients, it is our clients which are solely responsible for any such data, including personal data. We are not a controller of such personal data. You should contact these clients directly with any questions you may have about the use of your personal data, or if you wish to exercise your rights in relation to such personal data.
We may make changes to this policy and any such changes shall be posted on this page and will apply to your continued use of the Website.
The Website may from time to time, contain links to websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites are not required to comply with this policy and will likely have their own policies. We do not accept any responsibility or liability for the handling of your personal data by these other websites. Please check the privacy policies of these websites to ensure you are satisfied before submitting any personal data to these websites.
v2.0, 16 January 2019