1. Introduction
1.1 Innovation and Insight (“IN2”, “we”, “us”, “our”) is committed to protecting the privacy and security of the personal data we collect about clients, suppliers, and website users (“you/your”).
1.2 IN2 is committed to the protection of the Personal Data we Process in line with the data protection principles set out in the UK General Data Protection Regulation, the UK Data Protection Act 2018, and the Turkish Personal Data Protection Law n. 6698 (“the Laws”).
1.3 This privacy notice explains what personal data IN2 collects from individuals who visit our website, contact us by email, phone or through one of our social channels or by other means of communication (“you/your”). It also explains what information we collect automatically when you visit our website.
1.4 Where you make an enquiry with us about our services or visit this website, IN2 is the data controller for the purposes of the Laws.
1.5 As an information-led business, we place great importance on ensuring the quality, confidentiality, integrity and availability of the data we hold, and in meeting our data protection obligations when processing personal data. IN2 is committed to protecting the security of your personal data. We use a variety of technical and organisational measures to help protect your personal data from unauthorised access, use or disclosure. 1.6 If you have applied for a job with IN2 or submitted your CV (or similar employment information) to us, we process your personal data as set out in our privacy notice for recruitment candidates which can be obtained by emailing [email protected].
1.7 We update this privacy notice from time to time in response to changes in applicable laws and regulations, to our processing practices and to the services we offer. When changes are made, we will update the date at the top of this document. Please review this privacy notice periodically to check for updates.
2. What Information Do We Process
2.1 Information you provide to us
2.1.1 We process all information you give us, either through forms on our website or by corresponding with us by telephone, email or otherwise. This includes information you provide when you email us, subscribe to a service, search for a service, participate in our social media functions, or when you report a problem with our site.
2.2 Information processed following an enquiry
2.2.1 We may process the following information:
- Your name.
- Your job title/position.
- Organisation name.
- Organisation address.
- Organisation telephone number.
- Organisation email address.
2.2.2 We use your name, address, email address and phone number to contact you about your enquiry.
2.2.3 Indirectly, we may record additional details about you from other public information sources, such as LinkedIn, news articles and public registers.
2.3 Information we receive from other sources
2.3.1 We work closely with third parties including business partners, subcontractors in technical, payment and delivery services, website analytics providers and search information providers like Google and Linked-In and, therefore, may receive information about you from them.
2.4 Cookies
2.4.1 IN2 uses cookies on our website. Cookies are small text files which are downloaded to your de-vice when you visit a website, unless you have set your browser to reject them. We use cookies to re-member your preferences, display content that is more relevant to you and improve your overall experi-ence of our site.
2.4.2 To learn more about cookies, and what you can do to opt out of receiving them, please view our Cookies Notice. Our website contains links to other websites. This privacy notice only applies to this website, so please read the privacy notices provided by the other websites before posting any personal information.
3. Purposes And Bases For Processing Your Data
3.1 We may use your data for the following purposes and on the following lawful bases:
| Purpose | Lawful Bases for Processing |
|---|---|
| Responding to correspondence from you. | It is in our legitimate interest to respond to enquiries made by email, through our social channels or any other means. |
| Sending you information such as our news-letter, research reports, insights and other IN2 news and information which may be of interest. | When you agree to be contacted for marketing, we will rely on your consent, which may be withdrawn at any time by contacting us. |
| Fulfilment of our obligations, as set out in our agreement of services. | This is necessary for the performance of the contract we have entered with you. |
| Business management, forecasting and statistical purposes. | It is our legitimate interest to identify areas for managing current business relationships, develop new services, and for managing our business. |
| Improving our website and the overall website visitor and user experience. | It is our legitimate interest to allow analytics and search engine providers to help improve and optimise our website. We use cookies on our website with your consent. |
4. Sharing Your Information
4.1 Background
4.1.1 It is possible that we may be required to share your data to comply with applicable laws or with valid legal processes, in response to a court order or with government or law enforcement agencies. The legal basis in these cases is compliance with a legal obligation.
4.2 Transferring personal data outside the UK
4.2.1 We may share your personal data with third-party service providers located in countries outside the United Kingdom where the data protection laws are not equivalent to those within the UK. We do so use Standard Contractual Clauses approved by the European Commission and recognised by the UK which contractually oblige companies in those countries to meet the standard expected within the EEA.
4.3 Transferring personal data outside the Republic of Turkey
4.3.1 We may share your personal data with third-party service providers located in countries outside the Republic of Turkey where the data protection laws are not equivalent to those within Turkey. We do so with your explicit consent and the commitment to provide an adequate level of protection and, if applicable, with the permission of the Personal Data Protection Board where this permission has been given.
5. Your Rights
5.1 You have certain rights in relation to the processing of your personal data, including to:
- Request access to personal data about you (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 rectification, correction, or updating to any of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request personal data provided by you to be transferred in machine-readable format (“data portability”).
- Request erasure of 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 personal data where you have exercised your right to object to processing (see below).
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you (e.g. if you want us to establish its accuracy or the reason for processing it).
- Object to the processing of your personal data in certain circumstances. This right may apply where the processing of your personal data is based on the legitimate interests of IN2.
5.2 Additional rights for those data subjects in the Republic of Turkey are:
- Request confirmation of third parties in the Republic of Turkey or abroad to whom personal data have been transferred.
- Request compensation for the damages where you incur damages due to unlawful processing of personal data.
5.3 These rights are not absolute and are subject to various conditions under applicable data protection and privacy legislation and the laws and regulations to which we are subject. If at any time you decide that you no longer wish to be contacted for marketing purposes, or if you would like to exercise any of your rights as set out above, you can contact us by email to [email protected].
5.4 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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
5.5 In addition to the above, please note that you have the right to make a complaint at any time to the relevant a supervisory authority:
- Under the GDPR if you believe we are infringing UK data protection laws you have the right to make a complaint at any time to the Information Commissioner’s Office.
- For individuals in the Republic of Turkey have the right to lodge a complaint with the Personal Data Protection Board (KVKK) if you believe we are infringing Turkish data protection laws.
6. Data Retention Period
6.1 We will retain your personal data for as long as it necessary for the purpose of our relationship or until you object to us processing it or withdraw your consent.
7. Contact
7.1 You can contact IN2 in relation to data protection and this privacy notice by email us at [email protected]