Privacy Notice -
ImPrOve Think Tank

Who we are

Our site is operated by ImPrOve Think Tank (we).

Please contact us at: improve@havasso.com

How do we collect information?

We obtain limited information about you when you use our website, contact us, or if you sign up to our newsletter or attend one of our events.

What type of information is collected?

Submitted information:

We may collect and process the following personal information about you:

• contact details (such as your name, address, email address and telephone number); and
• your marketing preferences.

Additional information:

If you contact us with a complaint or query, we may keep a record of any phone number used to call us as well as the correspondence and the period of time it took for us to deal with a query or any request you had.

When you visit our website, we may also collect information from you automatically, for example using cookies and other similar technologies. A cookie is a small file of letters and numbers that we may set on your device.

The type of information collected may include:

• information about your device operating system and IP address;
• browser type and version; and
• information about your visit on our website including URL, clickstream (i.e. your journey to, through and from our site), length of visits to certain pages, and page interaction information;
• The cookies we use fall into the following categories:
• Session cookies: These allow our site to link your actions during a particular browser session. These expire each time you close your browser and do not remain on your device afterwards.
• Persistent cookies: These are stored on your device in between browser sessions. They allow your preferences or actions across the site to be remembered. These will remain on your device until they expire, or you delete them from your cache.
• Strictly necessary cookies: These cookies are essential for you to be able to navigate the site and use its features. Without these cookies, the services you have asked for could not be provided.
• Performance cookies: These cookies collect information about how you use our site, e.g. which pages you go to most often.

If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies or otherwise withdraw your consent in relation to cookies, you may not be able to access all of the functions of the site.

How we use, store and keep your personal information

We may use your information to:

• carry out our obligations arising from any contracts entered into by you and us;
• seek your views or comments on the services we provide;
• notify you of changes to our services; and
• send you communications which you have requested (such as our newsletters).

We take steps to ensure that the personal information that you provide is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymised. We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim.

Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information. However, please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.

The personal information that we collect may be transferred to, and stored at, a destination outside the EEA or the UK, including countries, which have less strict, or no data protection laws, when compared to those in the EEA or the UK. Whenever we transfer your information in this way, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy notice. In these cases, we rely on approved data transfer mechanisms (such as standard contractual clauses) to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.

Legal basis for processing your information

We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:

• Consent: For example, where you have provided your consent to receive newsletters etc. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of our email newsletters.
• Our legitimate business interests: Where it is necessary for us to understand our audience, promote our services and operate effectively, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights.
• Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

Who has access to your information?

We do not sell or rent your information. We do not share your information with third parties for marketing purposes. For example, we don’t share your email address with other companies so that they can advertise to you.

We may disclose your personal information to other third parties in the following cases:

• to third party service providers working on our behalf- we may pass limited information to our third party service providers, so that they can complete tasks for us and provide services to you on our behalf;
• for the purposes of research, evaluation, and analysis;
• in the event that we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets
• if we or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers and visitors to our websites will be one of the transferred assets;
• if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request; or
• to protect the rights, property or safety of us or our users, or others, and in order to enforce or apply our terms and conditions (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

Your choices and rights

We do not send newsletters without obtaining prior consent. If you no longer wish to receive them, you can unsubscribe at any time by clicking the “unsubscribe” link in the newsletter.

You have certain rights in relation to your personal information. These include: the right to object to the processing of your information for certain purposes, the right to access your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information.

We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights please contact us using the contact details above.

You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns we request that you initially contact us (using the contact details above) so that we can investigate, and hopefully resolve, your concerns

Links to other websites

Our website may contain links to other websites run by other organisations. This privacy notice applies only to our website. If you follow a link to any of these websites and/or services, please note that they have their own privacy notices and we do not accept any responsibility or liability for them. Please check any such third party privacy notices before you submit any personal information to these websites or services.

Changes to this privacy notice

We may change this privacy notice at any time. The new privacy notice will be displayed on our website. The date this privacy notice was last updated appears at the bottom.

THIS PRIVACY NOTICE WAS LAST UPDATED ON 21 SEPTEMBER 2021.