Privacy policy

Privacy Statement
IMG Sales Programs Pty Ltd Trading as Incremental Marketing

Introduction

Welcome to IMG Sales Program’s Marketing Website Privacy Policy.  IMG Sales Programs trading as Incremental Marketing (“IMG”) is a regional incentive, loyalty and sales promotion agency specialising in sales and channel incentive solutions, reward fulfilment and travel incentives.

Purpose

IMG respects your privacy and is committed to protecting your personal data. This Privacy Policy 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 Policy aims to give you information on how IMG collects and processes your personal data through your use of this website.

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 Policy together with any other Privacy Policy or fair processing policy 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 Policy supplements other notices and privacy policies and is not intended to override them.

Controller

IMG is the controller and responsible for your personal data (referred to as “IMG”, “we”, “us” or “our” in this Privacy Policy).

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 Policies. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

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 (anonymised 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 title, first name, last name.
  • Contact Data includes email address, home address, work address, phone numbers, company name, role
  • 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.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We generally do not seek data that may be considered “special” or “sensitive” personal data (e.g., government-issued identification numbers or information related to an individual’s racial or ethnic origin, political opinions, religious or other beliefs, health, criminal background, or trade union membership) from visitors of this Website, and we ask that you do not provide such data. If we specifically require “special” or “sensitive” personal data in connection with one or more of the uses described below, we will request your consent to use the data in accordance with this Privacy Policy and/or in the ways described at the point where you were asked to disclose the data. If you voluntarily share with us or post/upload any “special” or “sensitive” personal data to this Website for any other reason, you consent that we may use such data in accordance with applicable law and this Privacy Policy.

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 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:

  • apply for our products or services;
  • send us your CV
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, 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.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources which may be based outside the UK as set out below:

    Technical Data from the following parties:

  • analytics providers such as Google;
  • Social Media networks such as LinkedIn; and
  • search information providers.
  • Identity and Contact Data from data brokers
  • Identity and Contact Data from publicly available sources such as LinkedIn.

Please note that social media websites or webinar/video platforms hosted by a third party other than IMG may also collect information about you.

How we use your personal data

We will only use your personal data when the law allows us to.

  • We use personal data about you for the purpose(s) for which it was collected or provided to us (as stated at the point of collection) or as otherwise obvious from the context of collection. We may also use data to:
  • Administer and manage this Website, communicate with you about this Website, process your request for information, or otherwise complete a transaction or service you request or authorise;
  • Customise or personalise your user experience and the content we deliver to you, including to provide you with content that is more relevant to you;
  • Contact you about IMG’s products and services, provide you with promotional materials or offers for products/services from IMG, or send you other communications about IMG’s business and events (including communications based on your interests, personal and business characteristics, and location) (collectively, “marketing communications”). We may provide these communications and offers via email, postal mail, online, social media platforms, text messages, and other means;
  • Protect the rights, safety, property, or operations of one or more IMG affiliates, you, or others;
  • Comply with applicable law and/or respond to requests and communications from law enforcement authorities or other government officials.

Marketing

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

Note that you may unsubscribe from a IMG mailing list or any form of marketing communications at any time by clicking on the ‘unsubscribe’ link in any of our marketing communications to you. After you unsubscribe, we will not send you further marketing communications, but we may continue to contact you to the extent necessary for the purposes of any services you have requested. To unsubscribe from all communications please email in**@*********************co.uk

Promotional offers from us

We may use your Identity, Contact, Technical, Usage 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 products, 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 you have not opted out of receiving that marketing.

Third-party marketing

We will never use your personal data to advertise, promote, or market third-party goods or services to you. Additionally, we will not license or publish any of your personal data. We do not and will not sell any personal data to third parties for their own commercial use.

Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review and will be updated when necessary to do so, please regularly review it.

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.

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.

Disclosures of your personal data

In connection with one or more of the purposes outlined in this Privacy Policy,  we may disclose your information to:

  • Other entities within the 212F group of companies;
  • third parties that provide services to us, such as, but not limited to, website or system hosting, management, and support; data back-up; data analysis; security and storage services; IT infrastructure services; customer service; and email delivery services;
  • relevant third parties as part of corporate transactions, such as a reorganisation, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding);
  • competent governmental and public authorities, in each case to comply with legal or regulatory obligations or requests and in each case IMG will review and challenge where appropriate to do so to ensure your rights and freedoms are protected;
  • and other third parties as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to enforce our terms and conditions; (d) to protect our operations or those of any of our affiliates; (e) to protect our rights, privacy, safety, or property, and/or those of our affiliates, you, or others; and (f) to allow us to pursue available remedies or limit the damages that we may sustain.

International transfers

The processing of your personal data may result in the transfer of your information to countries or regions with data protection laws that differ from those in your country of residence. By providing us with your information, as described in this Privacy Policy, you are acknowledging that your information may be transferred to countries outside of your country of residence.

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.

In cases where your data is transferred outside of your country of residence, we take steps to ensure that appropriate safeguards are in place to protect such data. If you are based in the UK/EU/EEA, such safeguards may include a data transfer agreement with the data recipient based on standard contractual clauses or such other mechanism as is approved by the relevant supervisory Commission for transfers of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.

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.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • 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.
  • 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.

Who to contact to exercise your rights

If You have any questions or concerns related to how your personal date is used by us, you should contact IMG directly by sending an email with your name and contact information to Data Protection Manager mail to: in**@*********************co.uk

If you are not happy with the response you receive, or you believe that protection of your personal information or privacy rights have been infringed, you should contact Your European Union, United Kingdom, or other state or country’s Data Protection Authority (DPA) or if you are a citizen of Switzerland, the Swiss Federal Data Protection and Information Commissioner, as applicable.  You can search for Your country’s DPA by entering the name of your country combined with the words “data protection authority” or “privacy office” into an Internet search page such as www.google.com.

Basis for processing personal data.

Applicable law in certain countries requires us to set out in this Privacy Policy the legal basis upon which we rely in order to process personal data.

Consent: We may rely on the consent that you provide us at the point of data collection or disclosure to us to process such data for the purposes outlined herein.

Legitimate interests: We may rely on our legitimate interests to process your personal data, provided that our interests are not overridden by your interests, fundamental rights, or freedoms. In particular, we may process your personal data in reliance on a legitimate interest in the effective and lawful operation of this Website and our businesses, as well as the effective delivery of information and services to you. We may have other legitimate interests and, if so, we will make clear what those interests are at the relevant point in time.

Compliance with legal obligations: We may process your personal data if necessary for us to comply with a legal obligation arising under an applicable law to which we are subject.

To the extent that we process any “special” or “sensitive” categories of personal data relating to you, we will do so because either: (i) you have given us your explicit consent to carry out such processing; (ii) the processing is necessary for the establishment, exercise, or defence of legal claims; or (iii) you have made the data manifestly public.

Privacy policy update 15 September 2024