Privacy Policy

Welcome to IMAGINE‘s privacy policy.

Imagine World Ltd (collectively referred to as “IMAGINE”, “we”, “us” or “our”) are committed to protecting and respecting your privacy. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This policy will apply when you interact with us by any means, for example, through visiting our website, signing up to our newsletter, applying to our Learning Journeys, taking part in a survey, sending us feedback, or otherwise engaging with our services.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read and understand this privacy policy. Your use of this website means that you accept and agree to abide by this policy.

1. General information

Who we are

IMAGINE is the controller for the purpose of data protection legislation and we are responsible for your personal data.

Changes to this privacy policy

We may review this privacy policy from time to time by amending this page. We will send you an e-mail or post an update notice on our website so that you become aware of any updated version of this policy. This privacy policy was last updated on April 8th, 2022.

You are advised to review this privacy policy regularly for any changes. Changes to this policy are effective when they are posted on our website.

Third-party links

IMAGINE’s website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy. We do not control these third-party websites and we are not responsible for their privacy statements.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes full name, username or similar identifier, date of birth and gender.
Contact Data includes email address and/or telephone numbers.
Professional Data includes your organisation’s name, your job title and/or role.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, requests made by you in connection with the services, your interests, preferences, feedback and survey responses.
Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

On a few occasions, we may collect Special Categories of Personal Data where such information is necessary for the performance of our services (for example, this includes information about your ethnicity that may be requested when you are taking part in a survey or in our Learning Journeys).

We also collect, use and share Aggregated Data such as 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. 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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you (or your organisation) and you fail to provide that data when requested, we may not be able to provide you with our services.

3. How is your personal data collected?

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

Direct interactions. You may give us your personal information by filling in forms on our website, or by getting in touch with us by email or otherwise. This includes personal data you provide when you:
apply for our services;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Third parties. We may receive personal data about you from various third parties, [including analytics and search information providers such as Google.]

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Necessary for entering into or performing a contract. In order to perform obligations which arise under any contract we are about to enter into or have entered into with you (or your organisation).
Necessary for the purposes of legitimate interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Necessary for compliance with a legal obligation. We are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your information to a regulatory body or law enforcement agency.
In some circumstances, we may ask for your consent to process your information in a particular way (for example, when you give us information about your ethinicity whilst taking part in a survey run by us). Whenever you give us your consent, you have the right to withdraw that consent at any time by contacting us.

5. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing
To register you as a new customer	(a) Identity (b) Contact (c) Professional	Performance of a contract with you (or your organisation)
To manage our relationship with you which will include: (a) Providing you with the services (b) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Professional (d) Profile (e) Marketing	(a) Performance of a contract with you (or your organisation) (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how users use our services)
To enable you to complete a survey	(a) Identity (b) Contact (c) Professional (d) Profile (e) Marketing	(a) Performance of a contract with you (or your organisation) (b) Necessary for our legitimate interests (to study how users use our services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content/ advertisements to you and measure the effectiveness of our advertising strategy	(a) Identity (b) Contact (c) Profile (d) Ttechnical (e) Marketing	Necessary for our legitimate interests (to study how users use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationship and experience	(a) Technical	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Profile (e) Marketing	Necessary for our legitimate interests (to develop our services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

We may send you marketing communications from time to time about our new services provided that we obtain your consent to do so. If you no longer wish to receive marketing messages from us, you have the right to opt-out at any time by following the instructions in the “Opting-out” section below.

If you have already purchased services from us, we may send you electronic marketing communications about products we feel may interest you (based on your prior experience with us) if you have not opted out from that marketing messages.

Third-party marketing

We do not share your personal data with any third party for marketing purposes and we will get your express opt-in consent if we decide to do so.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

We may share your personal data with certain third-parties that will assist us with the provision of the services to you. This includes, for example, Mailchimp who provides us with our email marketing platform, Salesforce who provides us with our contact management system and Typeform who provide us with application platform services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

We do not transfer your personal data outside the UK.

8. Data security

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

9. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil 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 in 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 unauthorised 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 some circumstances you can ask us to delete your data: see ‘your legal rights’ below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

IMAGINE would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access—You have the right to request copies of your personal data from IMAGINE.
The right to rectification—You have the right to request that IMAGINE correct any information you believe is inaccurate. You also have the right to request that IMAGINE complete any information you believe is incomplete.
The right to erasure—You have the right to request that IMAGINE erase your personal data, under certain conditions.
The right to restrict processing—You have the right to request that IMAGINE restrict the processing of your personal data, under certain conditions.
The right to object to processing—You have the right to object to IMAGINE’s processing of your personal data, under certain conditions.
The right to data portability—You have the right to request that IMAGINE transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at [email protected].

No fee usually required

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.

11. Contact details

If you have any questions about this privacy policy or our privacy practices, please do not hesitate to contact us at [email protected].

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.