Privacy Policy

1. Who we are

Company Information

Company legal name: illio Holdings Limited

Company address: 85 Great Portland Street, London, W1W 7LT, United Kingdom

Privacy queries email: privacy@illio.com

Name of DPO: Peter Kasprowicz

2. Our Role

When we provide our services to our Customers, we are acting on their behalf as their service provider and processor. If you are a user that is using our service on behalf of one of our customers, your personal data is processed in accordance to:

• data protection legislation
• instructions given to us from the Customer
• the section in our Privacy Policy that talks about our Customers, Leads, Website Visitors and
• the Privacy Policy of the Customer, which is made available by them (normally on their website)

3. Information we collect about you

These are the categories of data we may process:

• Contact Details: examples include real name, email address, address, telephone number, social media username, title, physical address.
• Financial Data: examples include credit card number, credit card verification number (CCV), credit card expiry date, bank account number, billing address, transaction code (TAN), income information, VAT number, credit score.
• Communications Data: examples include instant messaging data, social media posts, postal content.
• Technical Identifiers: examples include IP address, MAC address, usernames, passwords, browser data, other device identifiers, unique identifier.
• Activity and Behavioural
• Aggregated Data: examples include statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 Policy.

This is just an overview, please see the following sections for more detail.

4. Legal justifications we rely on to process personal data

We process personal data for the purposes described in this policy, based on the following legal bases:

• Consent: the individual has given clear consent for us to process their personal data for a specific purpose.
• Legitimate interests: we have a business or commercial reason to use process your personal data, so long as this is not overridden by the individuals' own rights and interests.
• Contractual Obligations: the processing is necessary for a contract we have with the individual, or because they have asked us to take specific steps before entering into a contract.
• Legal Obligations: the processing is necessary for us to comply with the law.

5. How we process personal data of our Customers

Personal data

WHEN ACTING AS A PROCESSOR

When functioning as a processor, we undertake information processing based on explicit directives provided by our Customers, who serve as the Data Controllers in this context. For additional insights regarding our data usage as a processor, you can request access to our Data Processing Agreement, or alternatively, refer to our Customer's Privacy Policy.

In the capacity of a processor, there might be instances where we handle Special Category Data pertaining to our Customer's Users. While it is infrequent for us to regularly process such specialized data, it's important to note that any such processing would strictly adhere to the permissions and exemptions established by the respective Customer acting as the Data Controller.

6. How we process personal data of our Users

Personal data

7. How we process personal data of our Leads

Personal data

WHEN ACTING AS A PROCESSOR

When functioning as a processor, we undertake information processing based on explicit directives provided by our Customers, who serve as the Data Controllers in this context. For additional insights regarding our data usage as a processor, you can request access to our Data Processing Agreement, or alternatively, refer to our Customer's Privacy Policy.

In the capacity of a processor, there might be instances where we handle Special Category Data pertaining to our Customer's Users. While it is infrequent for us to regularly process such specialized data, it's important to note that any such processing would strictly adhere to the permissions and exemptions established by the respective Customer acting as the Data Controller.

8. How we process personal data of our Website Users

Personal data

9. How we process personal data of our Website Visitors

Personal data

WHEN ACTING AS A PROCESSOR

When functioning as a processor, we undertake information processing based on explicit directives provided by our Customers, who serve as the Data Controllers in this context. For additional insights regarding our data usage as a processor, you can request access to our Data Processing Agreement, or alternatively, refer to our Customer's Privacy Policy.

In the capacity of a processor, there might be instances where we handle Special Category Data pertaining to our Customer's Users. While it is infrequent for us to regularly process such specialized data, it's important to note that any such processing would strictly adhere to the permissions and exemptions established by the respective Customer acting as the Data Controller.

10. How we process personal data of our Staff

Personal data

11. How we process personal data of our Temporary Staff

Personal data

12. How your personal data is collected

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

Direct interactions - you may give us information on your Contact Details, Identifiers, Financial Data... (all the categories that come through direct interactions) by filling in forms or by corresponding with us by post, phone, email, via our website or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account with us;
• subscribe to publications;
• request marketing to be sent to you; or
• give us feedback or contact us.

Automated technologies or interactions. - As you interact with our website and services, we will automatically collect Technical, Profile and Usage Data about your equipment, browsing actions, and patterns.

Third parties or publicly available sources. - We might receive personal data about you from various third parties or publicly available sources like the ones set below.

• Work-related data from online recruitment platforms or professional networks.
• Identity and Contact Data from publicly available sources such as Crunchbase, or other registries or marketing partners.

13. Third Parties & Sub-Processors

We might store or send personal data about you to various third parties set out below.

14. International Transfers

Some of our external third parties are based outside the UK and EEA so their processing of your personal data will involve a transfer of data outside the UK or EEA. Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• the country to which personal data is being transferred has been deemed to provide an adequate level of protection for personal data; or
• we use appropriate transfer mechanisms such as Standard Contractual Clauses or the UK International Data Transfer Agreement.

15. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized 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.

Where you have chosen a password that enables you to access certain parts of our applications, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

16. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill 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 with 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 unauthorized 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.

In specific scenarios where our role is designated as a data processor, the duration for which data is retained is not determined by us. Instead, this time period is set and mandated by the data controller, in accordance with their policies and regulatory requirements. This ensures a clear understanding and compliance with the data controller's guidelines and legal obligations.

17. Automated decision-making and profiling

Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).

18. Your Legal Rights

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 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 (see below), where we may have processed your personal data 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 personal data 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.

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.

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.

Make a complaint you have the right to make a complaint at any time to the relevant regulator

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 is clearly unfounded, repetitive, or excessive. Alternatively, we could 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 concerning your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

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

Cookie Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

1. Type of cookies we use

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Marketing or Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

2. Third Party Cookies

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical or performance or targeting cookies.

Strictly Necessary Cookies

Functionality Cookies

Analytical or Performance Cookies

Targeting Cookies

3. Managing Your Preferences

If you want to restrict or block the cookies that are set by our website, you can do so through your browser settings. Alternatively, you can visit www.internetcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers and devices. You will find general information about cookies and details on how to delete cookies from your device.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features that we offer or store your preferences and some of our pages might not display properly.