Privacy Policy

Website Privacy Notice

Last Updated: December 2019

Innovisk Capital Partners, LLP and our affiliated entities (“Innovisk,” “we,” “us”) are committed to privacy and to transparency in our information practices. In this privacy notice, we describe our collection, use, disclosure and processing of personal information that we collect online via our Website, as well as related to our products and services.

Overview of Our Collection and Use of Personal Information

This overview is intended to summarize key information about our information practices, which are further explained below. (Go directly to full privacy policy.) While the actual information we collect and our use of such personal information varies depending upon the nature of our relationship and interactions, the table below provides a general overview of the categories of personal information we may collect and the purposes for which we use such information.

Categories of personal information we collect How we use personal information
Name, contact information and other identifiers: identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Providing support and services and operating our Website

Analyzing and improving our business

Personalizing content and experiences

Advertising, marketing and promotional purposes

Securing and protecting our business

Defending our legal rights

Auditing, reporting, corporate governance, and internal operations

Complying with legal obligations

Customer records: paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information.
Protected classifications: characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.
Commercial Information: including records of real property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
Usage data: internet or other electronic network activity Information including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
Geolocation data: precise geographic location information about a particular individual or device.
Biometric information: physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, faceprint, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. (to the extent permitted and subject to applicable laws)
Audio, video and other electronic data: audio, electronic, visual, thermal, olfactory, or similar information such as, CCTV footage, photographs, and call recordings.
Employment history: professional or employment-related information.
Education information: education information and records.
Profiles and inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

Individual rights. Please see the Individual Rights and Choices section below for a description of the choices we provide and the rights you have regarding your personal information. If you are a California resident, please be sure to review the section Additional information for California Residents below for important information about the categories of personal information we collect and disclose and your rights under California privacy laws.

1. Scope

This privacy notice describes, generally, how Innovisk, in our capacity as a ‘controller’ or a ‘business’ under applicable laws, handles and processes personal information related to:

Our collection, use and disclosure and processing of personal information about individuals will vary depending upon the circumstances. This privacy notice is intended to describe our overall privacy and data protection practices. In some cases, different or additional notices about our data collection and processing practices may be provided and apply to our processing of certain personal information.

Personal information. In this privacy notice, our use of the term “personal information” includes other similar terms under applicable privacy laws—such as “personal data” and “personally identifiable information.” In general, personal information includes any information that identifies, relates to, describes, or is reasonably capable of being associated, linked or linkable with a particular individual.

Not covered by this notice. This privacy notice does not apply to job applicants and candidates who apply for employment through our job application portal, or to employees and non-employee workers, whose personal information is subject to different privacy notices which are provided to such individuals in the context of their employment or working relationship with Innovisk.

2. Controller and Responsible Innovisk Entity

The controller for your personal information we collect pursuant to this Policy is: Innovisk Capital Partners LLP (Reg. No. OC422373), 30 Fenchurch Avenue, London, England, EC3M 5AD.

3. Cross-border Transfer

Innovisk is a global company and the data that we collect from you may be transferred to, accessed, processed or stored in, and subject to requests from law enforcement in, jurisdictions outside of your home jurisdiction, including the United States, the European Union and other jurisdictions, in which we or our service providers operate. Some of these jurisdictions, including the United States, may not provide equivalent levels of data protection as your home jurisdiction. We have established safeguards to protect personal information that is transferred to other countries, including appropriate contractual protections. For more information on the appropriate safeguards in place, please contact us using the details below.

4. Personal Information Collected

We collect personal information directly from individuals, automatically related to the use of the Services and Website, and in some cases, from third parties (such as social networks, platform providers, payment processors, and operators of certain third-party services that we use). Generally, we collect your personal information on a voluntary basis. However, if you decline to provide certain personal information that is marked mandatory, you may not be able to access certain services or we may be unable to fully respond to your inquiry.

The personal information that we collect and process will vary depending upon the circumstances. For example, the personal information we may collect through our Website includes:

We may also collect additional personal information in providing our Services, operating our business, and interacting with individuals in the course of our business, which may at times include “sensitive” information (otherwise known as “special categories of personal information” under the GDPR), such as health records or criminal conviction data. In these instances, we will provide specific data processing information to you regarding how we may process that data and what rights you may have regarding such processing.

Sources of personal information we collect. We may collect personal information directly from you, as well as automatically related to your use of our Website and other services, as well as from third parties. For example, we collect personal information:

Categories of personal information we collect. While the personal information we collect varies—as explained above—depending upon the nature of the services provided or used and our interactions with individuals, we may collect the following categories of personal information (subject to applicable legal requirements and restrictions):

Certain laws, including the GDPR, required that we inform you of the legal bases for our processing of your personal information. Pursuant to the GDPR (and other relevant laws), we process personal information for the following legal bases:

Purposes for using personal information. While the purposes for which we may process personal information will vary depending upon the circumstances, in general we use personal information for the purposes set forth below. Where GDPR or other relevant laws apply, we have set forth the legal bases for such processing (see above for further explanation of our legal bases) in parenthesis.

Aggregate and de-identified information. We may de-identify personal information and create anonymous and aggregated data sets and reports in order to assess, improve and develop our business, products and services, prepare benchmarking reports on our industry and for other research, marketing and analytics purposes.

6. Disclosure of Personal Information

We disclose the personal information we collect as set forth in this section.

A. Purposes for Which We Disclose Personal Information

Innovisk may disclose your personal information to any Innovisk group company for the uses and purposes set out above, including for marketing the products and services offered by other businesses across the Innovisk group (subject to applicable laws). We may also disclose your personal information for the following reasons:

We request those external service providers to implement and apply security safeguards to ensure the privacy and security of your personal information. These third parties have agreed to confidentiality restrictions and to use of any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us.

Aggregate and de-identified information. We may share aggregate or de-identified information, which does not identify and is not linked or linkable to a particular individual, with third parties for research, marketing, analytics and other purposes.

B. Categories of Personal Information Disclosed.

Certain privacy laws (such as the CCPA) require that we disclose the categories of Personal Information that we have disclosed for a business purpose as well as the categories that we have “sold” (as that term is defined under the CCPA or other applicable laws). Please review the descriptions of the categories of personal information under the Personal Information Collected section above, for further descriptions of each category of personal information.
Disclosed for a business purpose. In general, we may disclose the following categories of personal information in support of our business purposes identified above:

Categories of personal information sold. While we do not disclose personal information to third parties in exchange for monetary compensation from such third parties, we do disclose or make available personal information to third parties, in order to receive certain services or benefits from them, such as when we allow third party tags to collect information such as browsing history on our Website, in order to improve and measure our ad campaigns. The CCPA defines a “sale” as disclosing or making available to a third party Personal Information in exchange for monetary or other valuable consideration. Pursuant to the CCPA, the categories of Personal Information that we may “sell” as defined under the CCPA includes:

7. Cookies and Tracking

Our Website may use first party and third-party cookies, pixel tags, plugins and other tools to gather device, usage and browsing information when users visit our Website or use our online services. For instance, when you visit our Website, our server may record your IP address (and associated location information) and other information such as the type of your internet browser, your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and the pages you view and links you click on our Website, as well as date and time stamps associates with your activities on our Website.

We use the information for security purposes, to facilitate navigation, to personalize and improve your experience while using the Website, to improve and measure our advertising campaigns and to better reach users with relevant advertising both on our Website and on third party Website. We also gather statistical information about use of the Website in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.

Cookies. Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of Website, such as time spent on the Website, pages visited, language preferences, and other anonymous traffic data. You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. However, if you select such a setting, this may affect the functioning of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access or log on to our Website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

Pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Website to, among other things, track the actions of users of the Website (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Website and response rates. We and our service providers also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version and internet browser type and version. This information is gathered automatically and stored in log files.

Third Party Analytics Tools. Our Website use automated devices and applications operated by third parties (e.g., Google Analytics), which use cookies and similar technologies to collect and analyze information about use of the Website and report on activities and trends.

Do-Not-Track signals. Please note that our Website do not recognize or respond to any signal which your browser might transmit through the so-called ‘Do Not Track’ feature your browser might have. If you wish to disable cookies on our Website, you should not rely on any ‘Do Not Track’ feature your browser might have.

8. Interest-based Advertising

On some of our Website, we may work with third-party ad networks, analytics companies, measurement services and others (“third-party ad companies”) to display advertising on our Website and to manage our advertising on third-party sites, mobile apps and online services. We and these third-party ad companies may use cookies, pixels tags and other tools to collect information on our Website (and on third-party sites and services), such as browsing history, IP address, device ID, cookie and advertising IDs, and other identifiers, general location information and, with your consent, your device’s geolocation information; we and these third-party ad companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.

You may also obtain more information about targeted or “interest-based advertising” and opt-out of many ad networks at the industry Website below:

9. Security

Innovisk has implemented technical and organizational security measures to protect the personal information we collect. [These measures are aimed at ensuring the ongoing integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.] Despite this, the security of the transmission of information via the Internet cannot always be guaranteed and you acknowledge this in your access and use of our Website. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the Contact & Comments section below.

10. Individual Rights and Choices

Marketing. You may opt out from receiving marketing-related communications from us on a going-forward basis by contacting us or by using the unsubscribe mechanism contained in each email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

Access, amendment and deletion. You may request to review, make amendments, have deleted or otherwise exercise your rights, under applicable privacy laws, over your personal information that we hold, subject to certain limitations under applicable law. You may submit a request to us related to your personal information by emailing us at privacy@innovisk.com.

We take steps in accordance with applicable legislation to keep your personal information accurate, complete and up-to-date. If you would like to review, correct, update, suppress, or restrict the processing of your personal information or request a copy of personal information about you, you may contact us by sending us an email at privacy@innovisk.com or sending your request by postal mail to the address provided in the Contact & Comments section below.

In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

To exercise your rights please contact us using the contact information below. Subject to legal and other permissible considerations, we will make reasonable efforts to honour your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Additional information for certain jurisdictions. Innovisk is committed to respecting the privacy rights of individuals under all privacy laws applicable to us. Some privacy laws require that we provide specific information about individual rights to applicable consumers, which we have set forth at the end of this Notice:

11. Retention Period

We will retain your personal information for the period necessary to fulfill the purposes outlined in this privacy notice unless a longer retention period is required or permitted by law. We may retain personal information for longer where required by our regulatory obligations, professional indemnity obligations or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others. With respect to the data and files we handle as a processor, we retain this personal information in accordance with our clients’ instructions.

12. Children and Minors

The Website and Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16.

13. Changes to our Privacy Notice

From time to time, we may change our Privacy Notice. The effective date set forth at the indicates the last time this Privacy Notice was revised. Checking this effective date allows you to determine whether there have been changes since the last time you reviewed the notice. We will notify you of changes to this privacy notice by posting the revised privacy notice on our Website.

14. Contact and Comments

If you have any questions or comments regarding this privacy notice, please contact our Global Risk and Controls Manager, 34 Lime Street, London EC3M 7AT, UK or at privacy@innovisk.com or toll free at 1-877-992-8258.

15. Additional Information for Residents in Certain Jurisdictions

In this section, we set forth additional information, as required under applicable privacy laws in certain jurisdictions.

A. California Residents

In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”), which requires that we provide California residents certain specific information about how handle their personal information, whether collected online or offline. This section does not address or apply to our handling of:

Categories of personal information that we collect and disclose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The table below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect, sell, and disclose to others for a business purpose. We collect these categories of personal information from the sources described in the Personal Information Collected section above, and for the purposes described in the Purposes and Legal Bases for Processing Personal Information section above.

Rights of California residents. California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.

Submitting Requests. Do-Not-Sell (Opt-out) Requests, Requests to Know, and Requests to Delete may be submitted by emailing us at privacy@innovisk.com.

We will respond to verifiable requests received from California residents as required by law. For more information about our privacy practices, you may contact us as set forth in the Contact and Comments section above.

B. European Union / European Economic Area

Residents of the European Union (EU) and the European Economic Area (EEA) have the following rights, under the GDPR, regarding their personal information:

  • Right to object: You have the right to object at any time to any processing of your personal information which has our legitimate interests as its legal basis. You may exercise this right without incurring any costs. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. The right to object does not exist, in particular, if the processing of your personal information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
  • Right to object to our use of your personal information for direct marketing purposes: You can request that we change the manner in which we contact you for marketing purposes. You can request that we do not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.