Privacy Policy • INNOVA

Introduction

This policy explains when, why and how we collect personal information from the people who visit our website, sign up or purchase any of our services or request or contact us in any other manner. The policy also details the conditions under which we may disclose the information to others and how we keep it secure.

While we encourage clients to read our privacy policy in full, we do have a number of guiding principles we operate our company by:

We will never sell your data on.
We will never share your data with any third party for their own marketing.
We will always keep your personal data secure by using strong encryption, abiding by data protection rules and by implementing good security practice.
We will never send you direct email marketing without your consent. Our client section & registration (unless manual registration is used) require you to explicitly opt-in and you are free to opt-out at any time using the unsubscribe link contained within the email or through your client area by managing E-mail Subscriptions.

If you are ever concerned or have question about how your personal data is collected or used, please contact us by filling in the form on the contact page

You can read our full privacy policy below.

Who we are

INNOVA LTD is registered at the following address:

World Trade Centre,

6 Bayside Rd,

Unit 1.02

Gibraltar

GX11 1AA

Company number: 101371

This policy (together with our terms of use Terms and Conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998 (the Act) and GDPR (General Data Protection Regulation), the data controller is INNOVA LTD, a company registered in Gibraltar under company number 101371 and with our registered office at World Trade Centre, 6 Bayside Rd, Unit 1.02, Gibraltar

When do we collect your personal data

We may collect data about you in the following ways:

By filling in forms on our website, this includes information provided at the time of registering to use our website, subscribing to any of our services, posting material or requesting further services.
If you contact us, we may keep a record of that correspondence.
We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
Details of transactions you carry out through our site and of the fulfillment of your orders.
Visiting our site, including, but not limited to, traffic data, location data and other communication data required for our own security, diagnostic, authentication and billing.

What personal data do we collect

If you are simply viewing our website then we will collect the following information within our logs:

IP Address (See cookies and IP addresses)

If you signup to use our services then we will collect the following information:

Name
Address
Email Address(s)
Telephone number(s)
IP address
Company Details

While not actively collected we may store any other personal information that you may disclose during tickets or emails.

Cookies and IP Addresses

IP Addresses

We collect IP address information for security (DDoS prevention, anti-hacking and fraud prevention), diagnostics and statistical analysis of traffic used for improvements to the performance and usability of our services, for GDPR purposes we collect this information under legitimate interest.

Cookies

A cookie is a small file saved on your computer that is used to help store preferences and other information that is used by websites you may visit.

We use cookies for the Following:

Authentication of users when logging in or out of our services.
Analysis of traffic to our website via Google Analytics (see Google Analytics).
Tracking of website preferences.

If you register with us or if you continue to use our site, you agree to the use of cookies.

You can block cookies by activating the setting in your browser on your local computer which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies you may not be allowed access to all or parts of our site.

Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies as soon as you visit our site.

Where we store and process your personal data

The data that we collect from you is stored on our server in Gibraltar and/or in the UK however it may be processed by staff operating inside and/or outside the EEA (European Economic Area) who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services.

By submitting your personal data, you agree to the processing of this data inside and/or outside of the EEA.

We take all steps necessary to ensure that your data, regardless of where it is processed, is treated securely and in accordance with this privacy policy and the GDPR (General Data Protection Regulation) which includes certification to ISO27001 standard.

How we use personal data

We use information held about you in the following ways:

To verify your identity.
To provide you with the products and services you have purchased from us.
To carry out our obligations arising from any contracts entered into between you and us.
To ensure that content from our site is presented in the most effective manner for your device.
To respond to queries.
To provide you with information, products or services that you request from us where you have consented to be contacted.
To notify you about changes to our service.
To send you marketing emails where you have given explicit consent.
To prevent fraud.
To detect, prevent and diagnose potential security breaches.

How your personal data is protected & Potential breach

We treat all data with the utmost care and take appropriate steps in compliance with data protection regulation to ensure it is kept safe.

All data we collect is done so over encrypted connections (https).
All data is stored behind state of the art firewalls, managed by our security team.
All data is access-controlled to ISO27001 standards.
All systems storing personal data have access logging.
All passwords are encoded at our end.
Some of our servers are subject to occasional penetration testing and are monitored for vulnerabilities and attacks.
We report data breaches to data controllers and/or clients
We keep a record of data breaches

Registration and Personal Information

Registration is not required in order to use or access our website. However, our website may make forums, comments, blogs, message boards or similar available to our visitors. You may be required to register for these features, particularly if you wish to register a domain name, hosting services or leave comment.

If you do register, and in the process provide us with personally identifiable information, rest assured that any such information you provide will not be shared with any third-party organisation.

Please note that if you post comments or articles to any forum, blog or message board on this site, any personally identifiable information you provide in those comments or articles may be read, collated and used by anyone viewing them. As such, we are not responsible for personally identifiable information you may choose to make available through these channels.

Again, if you provide us with your email address and/or name for the purposes of receiving communications from us, this information will not be shared with any third-party organization except with your express consent.

Legal basis for the collection and processing

Data protection law sets out the conditions under which personal data can be collected and which we use as the basis for collection and processing, these include:

Contractual obligations

When you purchase a service, we need to collect personal data to fulfill our legal contractual obligation, for example: so we can manage and invoice your account and contact you for technical support purposes.

Legal compliance

The law requires we collect and process data for certain purposes such as for keeping financial records (i.e. invoicing) and that we can comply with law enforcement requests for data.

Legitimate interest

We collect data under legitimate interest in a way that is reasonably expected as part of the day to day running of our business.

For example, we collect and log IP addresses for fraud protection and security as well as analysis of our site usage.

Consent

In certain cases, we may collect and process your data with your consent, for example our newsletter and offer emails. Consent to receive these can be withdrawn at any time.

Ads and Remarketing

We use Google AdWords re-marketing services on our blog and forum to display our ads on third party websites (including Google) to previous visitors of those pages, this is done in the form of a cookie that contains anonymous data regarding your visit.

If you have a Google account you can opt-out of receiving these ads here http://www.google.com/settings/ads

Google are also a member of the NAI (Network Advertising Initiative), you can also use their site to opt out here http://www.networkadvertising.org/managing/opt_out.asp

Who we share personal information with

Our internal staff.

Like many websites we use a number of third-party services for functionality. The following is a list of companies we share data with on a day to day basis. This list does not include services we share anonymous data with or that provide services on an ad-hoc basis such as IT contractors. All the suppliers below have been carefully selected to ensure they provide suitable protections under GDPR.

Mailchimp

Our newsletter and marketing email lists are managed through Mailchimp, these emails are opt-in, when you opt-in to our newsletter your name and email address will be added to our mailing list which is held securely on mailchimp’s servers, by opting in you agree to:

Transfer your contact information to MailChimp.
Store your contact information in our MailChimp account.
To being sent marketing emails from our MailChimp account (These will be for our services only).
To have tracked interactions for email marketing and ad placement purposes.

Emails are initiated and managed by ourselves.

Please see the section entitled “Newsletter and Marketing Emails” for information on how to opt out of these emails.

Maxmind

Maxmind is used for fraud prevention, if you make a purchase your IP address will be shared with Maxmind to determine the approximate location the order is being placed from and if the IP is a known source of fraud.

GlobalSign

If you purchase an SSL certificate you will be required to provide your name, address and contact details which will be used by Globalsign to register the certificate and perform vetting. GlobalSign may contact you by email, phone or post as part of the vetting process.

Tucows (OpenSRS)

Tucows are a domain registrar and owners of OpenSRS, when you register a domain with us you are required to provide contact details that are used to register your domain against. It is important to note that these details will be visible within the publicly searchable database called “whois”, we strongly advise customers when making a GTLD (Generic top-level domain) purchase to choose the whois privacy option which anonymises the whois database entry.

(It should be noted that prior to the 25 ^th of May 2018 all personal whois data will be anonymised by Tucows to comply with GDPR.)

Nominet

Nominet are the registration authority for .uk and .co.uk domains, when you register a .UK domain you are required to provide contact details that are used to register your domain against. It is important to note that these details will be visible within the publicly searchable database called “whois”, if registering the domain as an individual you can opt out of having details listed in the whois database, you cannot opt-out if registering for commercial use.

(Important: prior to the 25 ^th of May 2018 all personal whois data will be anonymised by Nominet to comply with GDPR.)

Janet

Janet is the domain registration authority for .ac.uk, .gov.uk, .gov.scot, .gov.wales and .llyw.cymru domains. If you register any of these domain with us then your contact details will be shared for the purpose of linking and verifying your registration.

Microsoft & Google Cloud

We use Microsoft Office 365 for document storage, email and collaboration. In some instances your personal data may be stored on Office 365 servers, any data stored there is encrypted at rest and is controlled by us.

Paypal

PayPal might collect some information in order to process the order. For domain registration account establishment your information might be shared with our registration partner. In both cases this is done over an SSL encrypted connection to their servers.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of supply Terms and Conditions and other agreements; or to protect the rights, property, or safety of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Google Analytics

Like many websites we use Google Analytics to collect anonymous data about the users of our sites such as how often they visit, what pages they visit, what time they visit, how long the stay and what country they are visiting from.

This data is collected using cookies and from your IP address, the resulting statistics are used for the following purposes:

Improving website usability
Tracking the success of marketing campaigns
Pattern analysis

You can prevent Google Analytics from collecting this information by installing the google opt-out browser addon: https://tools.google.com/dlpage/gaoptout

To learn how Google uses data collected from our own and partner sites please see the following link: https://policies.google.com/privacy/partners?hl=en-GB&gl=uk

How long we retain your data

Your data will be kept until it is no longer required for the purpose of its collection.

At the end of the retention period the data will either be deleted or anonymised so it can no longer be linked back to an individual.

Personal data linked to purchases or any other financial transaction are kept for a minimum of 6 years as required by law to retain financial data.

We might also keep required data, if there are any unsettled payments or disputes, as long as the disputes remain unresolved.

Your rights under GDPR

Under GDPR (General Data Protection regulation) you have a number of rights relating to your personal data, these will come into force on the 25 ^th May 2018, for further information please see https://ico.org.uk

Right to Restrict Processing

You have the right to request the restriction of processing your personal data where there is no legitimate interest for us to do so:

Where the accuracy of the personal data is contested, to restrict the processing until such time as the accuracy has been sufficiently verified.
Where you object to the processing (See Right to Object), and where we are considering whether there are legitimate grounds to override the request.
When processing is unlawful and you oppose erasure and request restriction instead.
If we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.

You can exercise the right at any time by contacting our team (see Contacting Us).

Right of Access (Access to Information)

The GDPR Act gives you the right to access information held about you.

You can exercise this right by contacting us (see Contacting Us).

We are required to verify your identify before processing any right to access request, once verified the data shall be provided within 28 days.

The data shall be provided free of charge however an admin fee may be applied where a request is manifestly unfounded or excessive, particularly if it is repetitive.

Right to Erasure (Also known as the right to be forgotten)

As an individual you have the right to request the erasure of any data we hold on you, this is not an absolute right, for example it does not override our requirement under law to keep financial data such as invoice information.

You can make a request where your personal data is no longer necessary in relation to the purpose for which it was originally collected/processed, for example if you cancel all services you have with us.

To make a right to erasure request please contact our customer services team (see Contacting Us).

Right to Rectification

The GDPR provides the right to have any personal data rectified that may be incorrect or incomplete.

Customers can update their own personal details via the client area however if this is not sufficient please contact our customer services team (See contacting Us).

Right to Object

You have the right to object to the processing of your personal data where there is no legitimate or lawful reason to do so.

To make a right to object request please contact our customer services team (see Contacting Us).

External links

Our site may, from time to time, contain links to and from external websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

What if you think that we are not complying to this statement?

If you believe we are not handling your information in accordance with our privacy policy, please contact us. If for some reason, you believe that we have violated our privacy policy, we will correct the error as soon as you notify us.

Changes to our Privacy Policy

We keep our privacy policy under regular review, you can always find the latest version at the URL below:

https://www.innova.gi/privacy-policy/

Contacting us

Questions, comments and requests regarding this privacy policy are welcomed, you can contact us in the following ways:

Existing customers can contact us by creating a ticket through the client area.
Email us at privacy@innova.gi
Call us on +350 200 66993
Or write to us at: INNOVA LTD, World Trade Centre, 6 Bayside Rd, Unit 1.02, Gibraltar, GX11 1AA