Privacy PolicyPRIVACY POLICYinspo is a product of
The Pay Index.Last modified: 6th September 2022Effective 6th September 2022. You can find the previous version of our Privacy Policy
hereContents:1. HOW INFORMATION IS PROVIDED TO US2. INFORMATION WE COLLECT ABOUT YOU3. INFORMATION WE RECEIVE FROM OTHER SOURCES4. HOW WE USE YOUR INFORMATION AND JUSTIFICATION OF USE5. WHERE WE STORE YOUR PERSONAL INFORMATION6. DISCLOSURE OF YOUR INFORMATION7. HOW LONG WE RETAIN YOUR PERSONAL DATA8. YOUR RIGHTS9. COOKIES10. THIRD PARTY WEBSITES11. CHANGES TO THIS POLICY12. CONTACTInformation About UsThe Pay Index Limited is registered in England and Wales, having its registered office address at c/o Haines Watts (Berkhamsted) Ltd at 4 Claridge Court Lower Kings Road, Berkhamsted, Hertfordshire HP4 2AF, UK (“our”, “us” or “we” or “The Pay Index”).
What Does This Policy Cover?
Protecting your data, privacy and personal information is very important to The Pay Index. This Privacy Policy (“Policy“) relates to services provided through our website at
https://thepayindex.com, and our subsidiary websites
https://inspo.uk and
https://inspo.onlineThis Privacy Policy applies to the personal data of:
any web user accessing our website;
individuals registering an account with us and providing personal data through the use of our service; [and]
any representative of a business or institution using our services provided to business or institutional users]]
(our “Website” and “Subsidiary Website") or using any of the services offered via the Website, such as The Pay Index widget on a client or partner website
Definitions
“End User” means any individuals using our services to access compensation data, products and services.
“Controller” means a person or company that decide the purposes for which personal data is used and how it is processed.
“Client” means any business user accessing our data services.
“Partner” means a third party that hosts The Pay Index widget on their website.
“Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations (collectively the “Data Protection Laws”).
“Client Microsite” is a self-contained collection of webpages built specifically for a client. These typically contain a login portal, and access to specific tools for the user to gain access to. They might also contain other learning documentation and videos.
“Student” (“Student”) means any user that is at school, college or already studying in university or higher education.
“Brand Ambassador” (“Ambassador”) means a person acting on behalf of The Pay Index as its representative and interacts with other University Students.
“Website” means a set of related web pages located under a single domain name namely
www.thepayindex.com, and our subsidiary websites
https://inspo.uk and
https://inspo.online For the purpose of the General Data Protection Regulation (the “GDPR”)
Website and Client Microsite/s Users
For all respective occasions above we ensure that we comply with existing Data Protection Laws.
Our Client Microsite/s and Website Users is only for those aged 13 or over (Year 9 plus)
Our Client Microsite/s and Website is only intended for use by persons aged at least 13 years of age. DO NOT USE THE PAY INDEX IF YOU ARE NOT AT LEAST 13 YEARS OF AGE.
How to contact us
If you wish to access an older version of our Privacy Policy, please click here or alternatively please contact us
dpo@thepayindex.com This policy (together with our Terms and Conditions and any other documents referred to therein), sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by The Pay Index.
Please read this privacy policy carefully to understand the types of information we collect from you, how we use that information, the circumstances under which we will share it with third parties, and your rights in relation to the personal data you provide to us.
1. HOW INFORMATION IS PROVIDED TO US VIA INSPO.UK
You will be asked to provide us with your information when you:
· fill in forms on our Website or app inspo.uk and inspo.online or correspond with us by phone, email or otherwise;
· report a problem with our Client Microsite/s; or
· complete any surveys we ask you to fill in (although you do not have to respond to these if you do not want to).
Where you enter any details relating to a third party, you must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us.
For the avoidance of any doubt, any reference in this Privacy Policy to your data shall include data about other individuals that you have provided us with.
2. INFORMATION WE COLLECT ABOUT YOU
The Pay Index acting as a Data Controller or as a separate Data Controller with our ClientIn respect of all End Users, with regard to each of your visits to our Website, Subsidiary Website Propella.uk, Subsidiary Websites inspo.uk, inspo.online or use of The Pay Index’s Client Microsite/s, we may automatically collect the following information:
· device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;
· technical information about your computer, including where available, your IP address, operating system and browser type, for system administration and analytical purposes; and
· details of your visits to our Website or Subsidiary Website Propella.uk or Subsidiary Websites inspo.uk, inspo.online including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs), details of whether you are using the Website, Subsidiary Websites inspo.uk, inspo.online.
The Pay Index acting as a Data ControllerIn respect of End Users of The Pay Index’s Client Microsite/s we collect the following types of information via inspo.uk / inspo.online / app acts as a Data Controller of such Personal Data which is captured as encrypted. Such Personal Data may include but is not limited to:
Contact information such as names, email addresses;
Gender;
Level of Education;
Company Name;
Industry;
Function;
Job Title;
Course;
Primary Major;
Graduation Year;
University;
Free School Meals;
Sexual Orientation;
Disability;
Year of birth;
Password;
[any information which you provide in any free text field provided for completion on our Websites or in the course of the provision of any of our Services.]
We also create, 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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.
Certain types of particularly sensitive personal data known as “special categories of personal data” are given additional protection under data protection laws. We current process the following types of special categories of personal data:
· Ethnicity
We invite End Users accessing our services to provide information about their ethnicity. The provision of this data is optional, and you will be able to access our services without providing this data. However, if you do choose to provide information about your ethnicity, this data will be used and stored in accordance with this policy.
3. INFORMATION WE RECEIVE FROM OTHER SOURCES
When using our Platform, we will be in contact with third parties who may provide us with certain information about you in order to enable your use of the Platform:
· Social networks connected to the services. If you provide your social network account credentials to us via the bio field or otherwise sign into the Platform, Website or Subsidiary Websites inspo.uk or inspo.online through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your Account with us.
· Partners. If you sign up to access inspo through a third party partner website, inspo and/or our partner may indicate that certain data will be shared with that third party.
4. HOW WE USE YOUR INFORMATION AND JUSTIFICATION OF USE
Use of personal information under data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the ground we rely on in respect of each type of personal data which we use, as described in the privacy policy.
The following legal bases apply to our routine use of your personal data:
· Contract performance: where the use of your information is necessary to enter into or perform a contract with you;
· Legal obligation: where we need to use your information to comply with legal obligations;
· Legitimate interests: where we use your information for one of more legitimate business purposes having appropriate regard to your rights and freedoms; and
4.A Purposes for the use of your Personal Data:
In respect of the use of the Platform, The Pay Index uses information held about you (and information about others that you have provided us with) in the following ways:
Types of Personal Data collected
Purpose for the use of Personal Data? Lawful BasisUniversity StudentsContact information such as names, email addresses;
Gender;
Level of Education;
Course;
Primary Major;
Graduation Year;
University;
Free School Meals;
Sexual Orientation;
Disability;
Year of birth;
Password
Inspo or Clients may request additional Personal Data to be processed for use of the Platform. To enable students to engage with The Pay Index platform. Contract performance, consent (to the extent you provide any sensitive personal data in any free text box, you are consenting to the processing of such sensitive personal data). To send monthly product communications and re-engagement communications for inactive accounts as part of the Platform Legitimate interest (to ensure the database is accurate and up to date and communicate with users). To administer and improve the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes in a pseudonymised manner. To ensure the content on our Platform is presented in the most effective manner for you and your computer or mobile device Contract performance, legitimate interest (to improve the Platform and report internally on usage and gain insight on user basis at a statistical level). To enable the Client/s to analyse University Student engagement data. Contract performance, legitimate interests (to allow the Client to assess how the platform is being engaged with).Ethnicity To collate statistical data Monitoring equality of opportunity.
Professionals/Executives, alumniContact information such as names, email addresses;
Gender;
Level of Education;
Company Name;
Industry;
Function;
Job Title;
Course;
Primary Major;
Graduation Year;
University;
Free School Meals;
Sexual Orientation;
Disability;
Year of birth;
Password;
To enable Professionals, University Alumni and Business School Students to engage with The Pay Index platform. Contract performance, consent (you have the right to opt out at anytime by contacting The Pay Index).Legitimate interest (to ensure the database is accurate and up to date and communicate with users). To send monthly product communications and re-engagement communications for inactive accounts as part of the Platform Legitimate interest (to ensure the database is accurate and up to date and communicate with users). To administer and improve the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes in a pseudonymised manner. To ensure the content on our Platform is presented in the most effective manner for you and your computer or mobile device Contract performance, legitimate interest (to improve the Platform and report internally on usage and gain insight on user basis at a statistical level). To enable the Client/s to analyse Professional, Alumni & Business School Student engagement data. Contract performance, legitimate interests (to allow the Client to assess how the platform is being engaged with). Ethnicity To collate statistical data Monitoring equality of opportunity. With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you with information, news, and offers on our services. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time by following the opt-out links on any marketing message sent to you.
You have the right to withdraw consent to marketing at any time by contacting us.We do not use your personal data in any automated decision making and/or automated profiling. We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.
5. WHERE WE STORE YOUR PERSONAL INFORMATION
Your Personal Data is maintained, processed and stored by us in the UK. Your Personal Data may be accessed from outside of the UK by our service providers and these countries may not offer an equivalent level of protection for personal data.
Your passwords are stored on The Pay Index’s servers in encrypted form. We do not disclose your account details to anyone except when legally required to do so. It is your responsibility to keep your password secure. Unfortunately, the transmission of information via the internet is not completely secure. Although The Pay Index will do its best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website or Client Microsite/s, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent any unauthorised access.
6. DISCLOSURE OF YOUR INFORMATION
We may also disclose your personal information to third parties in the following circumstances:
Purpose of disclosure and third party(s) to which disclosure might be made
Use JustificationThe Pay Index may share certain Personal Data with Clients and Partners where necessary for the provision of our services. Such Personal Data may include: Personal Data submitted in the creation of a The Pay Index account (such as name, email, etc)Contract performance, legitimate interest (to allow our service providers to provide the necessary services).If The Pay Index or substantially all of its assets are acquired by a third party, personal information about our Clients will be one of the transferred assets.Legitimate interest (to sell our Company or assets), Consent (for sensitive personal data).If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of The Pay Index, our Clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection. Legal obligation.We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime. Legal obligation (to cooperate with law enforcement and regulatory authorities).
7. HOW LONG WE RETAIN YOUR PERSONAL DATA
We will hold the above information for as long as is necessary for the purposes relevant to the use of such information, as set out in this privacy policy. Once your account is terminated or deactivated, we shall delete the personal data relating to your account within 14 days.
Some Personal Data may need to be retained for longer than this to ensure The Pay Index can comply with applicable laws and internal compliance procedures, including retaining your email address for marketing communication suppression if you have opted not to receive any further marketing. If information is used for two purposes, we will retain it until the purpose with the