If you have any questions about this Policy, please contact our data protection officer (“DPO”) [Rebecca.Ticehurst@iconrelocation.com].
What is personally identifiable information (PII)/Personal Data?
Personal data or PII means any information relating to a person who can be identified either directly or indirectly; it may include name, address, email address, phone number, credit / debit card number, IP address, location data, purchase history (“Personal Data”).
Purposes for which we process personal data
We will only process your Personal Data, in accordance with applicable law, for the following purposes:
- creating and maintaining your Customer account, if you become our registered Customer;
- providing our services to you in a personalised way, for example, we may provide suggestions based on your previous searches to enable you to identify suitable goods and services quicker. This may also include, where legally permitted, processing data related to your location;
- handling the provision of services to you. This may also include processing of information that we receive from third parties, for example, address data to verify your correct address;
- sending you personalised marketing communications, where you have agreed that we may do so, in order to keep you informed of our and our selected partner’s products and services, which we consider may be of interest to you;
- ensuring the security of your account and our business, preventing or detecting fraud or abuses of our website, for example, by requesting verification information in order to reset your account password;
developing and improving our services, for example, by reviewing visits to our website and its various subpages, demand for specific services and User comments; and
- to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.
Your consent, as the Data Subject, to the processing as specified in this Policy is the primary legal ground for our processing of your Personal Data. However, there may be circumstances where we may also rely on other valid legal grounds for the processing of your Personal Data, such as:
- your request for services necessitating steps including processing of your Personal Data to be taken prior to entering into contract with you and any processing that is necessary for the performance of such contract; and
- legitimate interests pursued by us as a business, except where such interests are overridden by your interests and fundamental rights. We will rely on this legal ground in relation to the processing set out in paragraphs 3.1.5 and 3.1.6, in which we have a legitimate interest; and
- compliance with a legal obligation to which we are subject, such as, for example, the processing for the purposes set out in paragraph 3.1.7.
Disclosure of customer information
There are circumstances where we wish to disclose or are compelled to disclose your Personal Data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:
- to our subsidiaries, branches or associated offices;
- to third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
- to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your Personal Data will be permanently transferred to a successor company;
- to public authorities where we are required by law to do so; and
- to any other third party where you have provided your consent
International transfer of personal data
We may transfer your Personal Data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out in paragraph 3 above. In particular, your Personal Data may be transferred throughout our group and to our outsourced service providers located abroad. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means.
Please contact the DPO for a copy of the safeguards which we have put in place to protect your Personal Data and privacy rights in these circumstances.
Retention of personal data
- Your Personal Data will be retained until completion of the provision of services to you and normally for a period of three years. thereafter, unless longer retention is required by applicable local law or where we have a legitimate and lawful purpose to do so. However, we will not retain beyond this period any of your Personal Data that is no longer required for the purposes set out in this Policy. The retention of your Personal Data will be subject to periodic review.
- We may keep an anonymised form of your Personal Data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
Data subject rights
- Data protection law provides Data Subjects with numerous rights, including the right to: access, rectify, erase, restrict, transport, and object to the processing of, their Personal Data. Data Subjects also have the right to lodge a complaint with the relevant data protection authority if they believe that their Personal Data is not being processed in accordance with applicable data protection law.
- Right to make subject access request (SAR). Data Subjects may, where permitted by applicable law, request copies of their Personal Data. If you would like to make a SAR, i.e. a request for copies of the Personal Data we hold about you, you may do so by writing to the DPO whose contact details are above. The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and a fee.
- Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete Personal Data.
- Right to withdraw consent. You may, as permitted by applicable law, withdraw your consent to the processing of your Personal Data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your Personal Data is essential.
- Right to object to processing. You may, as permitted by applicable law, request that we stop processing your Personal Data.
Right to erasure. You may request that we erase your Personal Data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your Personal Data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.
- Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your Personal Data. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions.
Please note that this website is not intended for children under the age of 16.