General Policy for the Protection of Personal Data

INRADIUM LIMITED, UK Companies House number 12979721, registered at Ye Olde Hundred, 69 Church Way, North Shields, NE29 0AE, United Kingdom (hereinafter referred to as “INRADIUM”) carries out the processing of personal data (as defined below) in the framework of its activity, which includes the Personal Data of persons who browse the INRADIUM websites (the “Site(s)”).

This “Personal Data Protection Policy” (the “Policy”) is intended to inform all individuals concerned (“You” or “Your”) of how INRADIUM collects and uses such Personal Data and the means you have to control this use.

INRADIUM never processes sensitive data that reveal your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data for the purpose of uniquely identifying an individual, data on the health, sexual life or sexual orientation of an individual, as it does not fall within the activity of INRADIUM and does not fulfil any purpose of the company’s processing operations.

1. SCOPE OF THIS PERSONAL DATA PROTECTION POLICY

The General Data Protection Regulation ("GDPR") applicable from May 25, 2018 is intended to apply to all companies that collect, store or process personal data. INRADIUM has put in place a strategy aimed at complying with this regulation (training of its employees, network information, reporting procedures, etc.); it is within this framework that this Policy has been drawn up.

INRADIUM collects or processes Personal Data online or offline; this Policy applies regardless of the method of collection or processing, provided that the processing is done through the INRADIUM Sites, or within the framework of the data collection and processing  services provided to INRADIUM customers.

The concept of Personal Data ("Personal Data") means any information relating to an identified or identifiable natural person (hereinafter referred to as "the data subject"). An “identifiable person” is an individual who can be identified, directly or indirectly by reference to an identifier, such as a name, identification number, location data, online identifier, or one or more elements specific to his physical, physiological, genetic, psychic, economic, cultural or social identity.

"Non-personal data" refers to information that does not identify a person.

Your use of the INRADIUM Sites, and the Personal Data you agree to communicate on the Sites, is subject to the provisions of this Policy and the applicable Terms of Use.

2. DATA COLLECTED FOR INRADIUM’S PRODUCTS AND SERVICES

INRADIUM creates profiles of business people and companies, which we call “Inradium Profiles”, from multiple sources. Once we have collected business information about a person or company from multiple sources we combine these data into a Inradium Profile. The resulting database of Inradium Profiles is then made available to our customers and strategic partners. Any data collected or provided to INRADIUM’s customers are focused entirely on people in their business capacity and not in their capacity as private individual consumers.

INRADIUM obtains the data for its Inradium Profiles in several ways including:

• Scanning the web or social media sites for      publicly available Information
• Extracting data from news articles
• Licensing information from other      companies.
• Business information contributed by the      users themselves including users of INRADIUM sites
• Through market research conducted by our in-house research team
   

Data included in an Inradium Profile may include the following:

• Name
• Email address
• Job title 
• Business biographies
• Business phone numbers 
• Company name(s)
• Postal address of company
• Business related postal address of person
• Corporate website URLs
• Social Networking URLs

In any case, the Personal Data collected will, however, be limited to the data necessary for the purposes set out in Article 4 below.

Personal Data may be collected via the Sites, it may also come from publicly available sources or, where appropriate, from INRADIUM partners subject to appropriate contractual safeguards.

3. PROTECTION OF THE PERSONAL DATA OF CHILDREN

INRADIUM products and services are not intended to be marketed to children under the age of 16 and INRADIUM does not voluntarily collect or store Personal Data of children under the age of 16.

INRADIUM products and services cannot be used by children. If the parents discover that their child has submitted Personal Data to INRADIUM, they may ask INRADIUM to delete the Personal Data and terminate the child's account by sending an email to: privacy@inradium.com.

If INRADIUM discovers that Personal Data of children under 16 has nevertheless been collected, it will take the necessary measures to delete such Personal Data and delete the child’s account.

4. PURPOSES OF THE COLLECTION OF PERSONAL DATA

Personal Data is collected for the needs of INRADIUM’s activity such as the provision of services by INRADIUM to its customers. Such services include the provision of data to help businesses maintain and optimise their business-to-business databases and providing Customers with marketing insights and defined audience segments. 

Data collected on customers and prospects via the Sites is used, with Your consent to keep You informed about the products and services provided by INRADIUM.  Data on our customers is never shared with third parties other than to comply the statutory reporting obligations.

5. COOKIES

The Sites may use cookies or other technologies that may collect or store Personal Data. Cookies are text files stored and used to record personal and non-personal data about Your browsing on the Sites. Cookies may be permanent (and remain after You log out of Sites for use in Your subsequent visits to the Sites) or temporary (and disappear as soon as You log out of the Sites).

INRADIUM uses cookies:

• To improve Your user experience, in particular by:
  • Allowing a service to recognise Your equipment, so you will not have to provide the same information multiple times in order to perform the same task,
• Analysing the traffic and the data on the Sites to:
  • Measure the number of users of the services, thus making them easier to use and ensure their ability to respond quickly to Your requests,
  • Helping INRADIUM to understand how users interact with services to improve them.

When you browse the INRADIUM Sites, cookies are enabled by default and data can be read or stored locally on your device. You will be notified the first time that You receive a cookie and You will be able to decide whether to accept it or not. By continuing to use the Sites, You expressly agree to INRADIUM's use of such cookies.

You can also configure Your browser to systematically refuse cookies (including cookies used for audience measurement purposes). However, if this were the case, some features and characteristics of the Sites may not work properly and You may not be able to access certain parts or services of the Sites.

6. CONDITIONS AND DURATION OF THE PROCESSING OF PERSONAL DATA

"Processing" of Personal Data includes the use, retention, registration, transfer subject to appropriate safeguards, adaptation, analysis, modification, declaration, sharing and destruction of Personal data according to what is necessary in view of the circumstances or the legal requirements.

All Personal Data collected is kept for an appropriate period depending on the purpose of the processing; respecting any durations provided for by the applicable legislation.

7. LINKS TO WEB SITES NOT CONTROLLED BY INRADIUM OR ITS SUBSIDIARIES

The Sites may offer links to third-party websites that may be of interest to You.

INRADIUM has no control over the content of third-party sites or the practices of these third parties with regard to the protection of Personal Data they may collect. Consequently, INRADIUM disclaims all responsibility regarding the processing of Your Personal Data by these third parties. It is Your responsibility to inquire about the privacy policies of these third parties.

8. TRANSFER AND RECIPIENTS OF PERSONAL DATA

In case of access to the Sites from a non-EU country whose legislation relating to the collection, use and transfer of data differs from that of the European Union, we draw your attention to the fact that by continuing to use the Sites, you transfer Your Personal Data to the European Union and consent to such transfer.

INRADIUM may transfer Your Personal Data outside the European Union, provided that it ensures, before transferring it, that entities outside the European Union, including affiliated companies and members of the INRADIUM distribution network, offer an adequate level of protection or are subject to appropriate safeguards, in accordance with European legislation.

If INRADIUM discovers that a third party to whom INRADIUM has disclosed Personal Data for the purposes set forth in Article 4 above uses or discloses Personal Data without complying with this Policy or in violation of applicable law, it shall take reasonable steps to prevent or put an end to such use or disclosure. INRADIUM may also be required to transfer Your Personal Data to third parties if it considers that such transfer is necessary for technical reasons (for example, for third-party hosting services) or to protect its legal interests (for example, in case of the sale of assets to a third-party company, change of control or total or partial liquidation of INRADIUM).

INRADIUM may also share your Personal Data with business partners when INRADIUM and the Business Partner jointly sponsor an event or participate together in a marketing promotion in which You engage.

INRADIUM may disclose Your Personal Data if required to do so by law or if it believes in good faith that such disclosure is reasonably necessary to comply with a legal procedure or to protect the rights, property or personal safety of INRADIUM, its customers or the public.

If permitted by the applicable law, INRADIUM may also share Your Personal Data with third parties in order to provide you with targeted marketing or advertising offers.

Such transfers may be made via the Internet or any other method deemed appropriate by INRADIUM in accordance with the applicable law.

9. RIGHTS OF DATA SUBJECTS ON THEIR PERSONAL DATA

INRADIUM has implemented appropriate Personal Data protection measures to ensure that Personal Data is used for the purposes described above and to ensure that it is accurate and up-to-date.

Pursuant to the GDPR and other applicable privacy laws, you have a right of access, rectification or erasure (right to be forgotten) on your Personal Data and, if necessary, a right to the portability of your data. You can request the limitation or oppose the processing of your data or, if necessary, withdraw your consent. You also have the right to obtain a copy of Your Personal Data kept by INRADIUM, as well as the right not to be the subject of an automated individual decision.

You have the legal right to lodge any complaint with the competent supervisory authority.

You can exercise Your rights by sending an email to the following address: privacy@inradium.com.

In the event of a request to exercise Your Rights which is clearly unfounded or excessive, INRADIUM reserves the right to charge the person making the request a reasonable amount to cover the costs related to the access, rectification or deletion operations or to refuse to comply with the request.

10. DATA SECURITY

INRADIUM shall protect and secure the Personal Data that You have chosen to provide it with, to ensure its confidentiality and prevent it from being deformed, destroyed or disclosed to unauthorised third parties, including when certain operations are carried out by subcontractors.

INRADIUM has taken physical, electronic, organisational and technical protective measures to prevent any loss, misuse, unauthorised access or dissemination, alteration or possible destruction of such Personal Data. Among these protective measures, INRADIUM integrates technologies specifically designed to protect Personal Data during its transfer. However, despite its efforts to protect Your Personal Data, INRADIUM cannot guarantee the infallibility of this protection due to the inevitable risks that may arise when transmitting Personal Data.

Access to Personal Data is limited to INRADIUM employees, service providers and agents who need it for the performance of their assignment. All persons having access to Your Personal Data are bound by a confidentiality obligation.

11. REPORTING OF INCIDENTS RELATING TO PERSONAL DATA

Although INRADIUM has taken reasonable steps to protect Personal Data, no transmission or storage technology is entirely infallible.

However, INRADIUM is anxious to guarantee the protection of Personal Data. If You have reason to believe that the security of Your Personal Data has been compromised or that it has been misused, You are invited to contact INRADIUM promptly at the following address: privacy@inradium.com.

INRADIUM will investigate the reports and will endeavour to resolve them as best as possible in accordance with the principles set forth in this Policy.

12. CONTACT

For any questions regarding this Policy, or for a request to exercise Your rights on Your Personal Data, You may send an email to the following address: privacy@inradium.com.

13. DATE OF ENTRY INTO FORCE AND REVISIONS OF THE PERSONAL DATA PROTECTION POLICY

This Policy may be updated according to the needs of INRADIUM and circumstances or as required by law. We therefore invite you to regularly check for updates.

Date of the last update: 10/05/2021