IME London Privacy Policy

Background

IME London understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, http://www.imelondon.co.uk (“our Site”) and will only collect and use personal data in ways that are described here, and in a manner, that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

“Account” means an account required to access and / or use certain areas and features of our Site;

“Cookie” means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and / or when you use certain features of our Site. Details of the Cookies used by our Site are set out in section 13, below;

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

“Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 amended by EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and

“We/Us/Our” means IME London, its subsidiaries in the UK registered in England Authorised and Regulated by the FCA for the provision of Payment Services;

2. Information About Us

2.1 Our Site is owned and operated by Subhida UK Limited. Company Reg No: 06432399.

2.2 Our Data Protection Officer is Mr. Kamal Paudel and can be contacted by email at kamal@imelondon.co.uk and by telephone on +442088660307 or by post at Pentax House, South Harrow, London, HA2 0DU

2.3 In the UK we are regulated by the Financial Conduct Authority (FCA).

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

• 4.1.1 The right to be informed about our collection and use of personal data;
• 4.1.2 The right of access to the personal data we hold about you (see section 12);
• 4.1.3 The right to rectification if any personal data we hold about you is inaccurate or incomplete;
• 4.1.4 The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you;
• 4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
• 4.1.6 The right to data portability;
• 4.1.7 The right to object to us using your personal data for particular purposes; and
• 4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 14 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?

Depending upon your use of Our Site, we may collect some or all the following personal and non-personal data (please also see section 13 on our use of Cookies and similar technologies and our Cookie Policy for detail, please refer to our Data Protection Policy and Privacy Notice.

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary considering the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Act 1998 as always amended by GDPR.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g., by subscribing to emails), or because it is in our legitimate interests. Specifically, We may use your data for the following purposes:

• 6.2.1 Providing and managing your Account;
• 6.2.2 Providing and managing your access to our Site;
• 6.2.3 Personalising and tailoring your experience on our Site;
• 6.2.4 Supplying our services to you;
• 6.2.5 Personalising and tailoring our services for you;
• 6.2.6 Replying to emails from you;
• 6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time);
• 6.2.8 Market research;
• 6.2.9 Analysing your use of our Site and gathering feedback to enable us to continually improve our Site and your user experience.

6.3 With your permission and / or where permitted by law, we may also use your data for marketing purposes which may include contacting you with information, news and offers on our services.

6.4 Third parties whose content appears on our Site may use third party Cookies, as detailed below in section 13.

6.5 You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.

6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods:

• 6.6.1 5 years since the date we concluded our last transaction or ended our relationship with our clients;
• 6.6.2 6 months for employment applications;
• 6.6.3 On an ongoing basis for employment purposes, and for 4 years after individuals leave employment.

7. How and Where Do We Store Your Data?

7.1 We only keep your personal data for as long as we need to in order to use it as described above in section 6, and / or for as long as we have your permission to keep it.

7.2 Your data will be stored in the UK, unless you request we provide you with off shore services, in which case your information will be shared with our Custodians outside the EEA.

7.3 Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our Site.

7.4 Steps we take to secure and protect your data include:

• 7.4.1 Appointment of a Data Protection Officer;
• 7.4.2 Implementation of a Data Management Framework, including policies, procedures and internal control mechanisms to ensure your data is secure and processed according to your rights.

8. Do We Share Your Data?

8.1 In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal obligations, a court order, or a governmental authority.

8.2 We may sometimes contract with third parties such as Custodians to provide services to you on our behalf. These may include payment processing, order processing and fulfilment of your instructions.

8.3 We may compile statistics about the use of our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised.

8.4 The third-party data processors used by us and listed in our Privacy Notice are located in the UK; we also may sometimes use third party data processors that are located outside of the European Economic Area.

8.5 In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.

9. What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce our business and this may involve the sale and / or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part.

9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.

10. How Can You Control Your Data?

10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via our Site, you may be given options to restrict our use of your data.

10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”).

11. Your Right to Withhold Information

11.1 You may access certain areas of our Site without providing any data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.

11.2 You may restrict our use of Cookies. For more information, see section 13.

12. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the GDPR, no fee is payable, and we will provide all information in response to your request free of charge. Please contact us for more details at info@imelondon.co.uk, or using the contact details below in section 14.

13. Our Use of Cookies

13.1 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by us and are used only by us.

13.2 By using our Site you may also receive certain third-party Cookies on your computer or device.

13.3 All Cookies used by and on our Site are used in accordance with current Cookie Law.

13.4 Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies.

13.5 The following first party Cookies may be placed on your computer or device:

13.6 Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our Site is used.

13.7 The analytics service(s) used by our Site use(s) Cookies to gather the required information.

13.8 The analytics service(s) used by our Site use(s) the following Cookies:

13.9 In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser.

13.10 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our Site more quickly and efficiently.

13.11 It is recommended that you keep your internet browser and operating system up-to-date.

14. Contacting Us

If you have any questions about our Site or this Privacy Policy, please contact us by email at info@imelondon.co.uk, by telephone on +442088660307, or by post at: IME London, Pentax House, South Harrow, London, HA2 0DU, UK.

15. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on our Site, and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up to date.