IMAGINEX Privacy Policy

OUR COMMITMENT TO YOUR PRIVACY

There are some changes in data protection law, so we wanted you to know that we’ve updated our Privacy Notice.

Your trust is important to us, and we want to make sure you understand what these changes mean for you.

So if you’d like to find out more, take a look at our Privacy Notice.

Protecting your privacy

IMAGINEX is a trading name of Imaginex Limited in the United Kingdom.

Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

1. Explaining the legal bases we rely on 

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you book a stand, we’ll collect your name and full contact information, plus payment details. 

Legal compliance

If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting the Partnership to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to send you or make available personalised offers.

We will also use your address details to send you direct marketing information by post or email telling you about products that we think might interest you.

3. When do we collect your personal data?

• When you make an online purchase
• When you purchase a product or service by phone
• When you engage with us on social media
• When you download or install one of our apps
• When you contact us by any means with queries, complaints etc.
• When you ask one of our Partners to email you information about a product or service.
• When you book to attend an event
• When you choose to complete any surveys we send you
• When you fill in any forms.
• When you’ve given a third party permission to share with us the information they hold about you
• When our Finance suppliers and partners share information with us about the product you have purchased.
• We collect data from publicly available sources when you have given your consent to share information or where the information is made public as a matter of law.

4. What sort of personal data do we collect?

• Your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
• Details of your interactions with us through all contact types, phone, at events, online or by using one of our apps.
• For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, brands you show interest in, web pages you visit and how and when you contact us.
• Copies of documents you provide to prove your identity where the law requires this. (including your passport and driver’s licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
• Details of your purchase preferences.
• Details of your visits to our websites or apps, and which site you came from to ours.
• Information gathered by the use of cookies in your web browser.
• Personal details which help us to recommend items of interest.
• Payment card information.
• Your comments and product reviews.
• To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit.
• Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your purchasing experience with us. Of course, it’s always your choice whether you share such details with us.

5. How and why do we use your personal data?

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you products and services that are most likely to interest you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service. Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

6. Here’s how we’ll use your personal data and why:

• To process any orders that you make by using our websites, telesales, apps or at an event. If we don’t collect your personal data during these processes, we won’t be able to process your order and comply with our legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
• To respond to your queries and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
• To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account.
• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
• If we discover any criminal activity or alleged criminal activity through our use of fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
• With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time.
• To send you relevant, personalised communications by post or email in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us at any time.
• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
• To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
• To comply with our contractual or legal obligations to share data with law enforcement.
• To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our events more relevant to you.
• Of course, you are free to opt out of receiving these requests from us at any time by by updating your preferences in our online account
• To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across the Partnership, third parties and data from publicly-available lists as we have described in the section What Sort of Personal Data do we collect? We’ll do this on the basis of our legitimate business interest.
• Sometimes, we’ll need to share your details with a third party who is providing a service (such as stand designers, printers, furniture providers). We do so to maintain our commitment to you. Without sharing your personal data, we’d be unable to fulfil your request.
• Combining your data for personalised direct marketing−
• We want to bring you offers and information on events that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across the Partnership as described above, for example your purchasing history.

7. How we protect your personal data

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of our websites and apps using ‘https’ technology.

Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by encryption.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

8. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Some examples of customer data retention periods:

Orders:

When you place an order, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations.

9. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties. For example, delivery couriers, stand designers, for fraud management, to handle complaints, debt collection etc.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure that your privacy is respected and protected at all times.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work with are:

• IT companies who support our website and other business systems.
• Operational companies such as delivery couriers.
• Direct marketing companies who help us manage our electronic communications with you.
• Data insight companies to ensure your details are up to date and accurate.
• Stand designers / graphic designers
• Debt collectors

Sharing your data with third parties for their own purposes (We will only do this in very specific circumstances, for example) :

• With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.
• For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
• We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

10. Where your personal data may be processed

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).

International orders

If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to the Partnership in the UK.

Protecting your data outside the Europe

This includes all EU Member countries as well as Iceland, Liechtenstein and Norway.

We may transfer personal data that we collect from you to third-party data processors in countries that are outside Europe such as the Middle East or North Africa. For example, this might be required in order to fulfil your order, process your payment details or provide support services.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside Europe. For example, our contracts with third parties stipulate the standards they must follow at all times.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

11. What are your rights over your personal data?

You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• That we stop using your personal data for direct marketing (either through specific channels, or all channels).
• That we stop any consent-based processing of your personal data after you withdraw that consent.
• Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).

You can contact us to request to exercise these rights at any time as follows:

To ask for your information please email – info@justimaginex.com

If we choose not to action your request we will explain to you the reasons for our refusal.

Your right to withdraw consent:

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest. In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation.

We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.

If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

12. How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

• Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
• Write to info@justimaginex.com

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

13. Finance

13.1 How we use your personal data

When you purchase a product or service, we might receive a copy of the information you supplied. If you agree to receive marketing communications from us, we will use your data to personalise what we send you. You are free to opt out of receiving marketing communications from us at any time. Find out more about the use of your data for marketing in section 7.

13.2 How our providers use your personal data

When you then apply for a product or service from one of our chosen providers, your data will be collected and used by them under the terms of their own separate privacy policies.

13.3 Joint use of your personal data

We may check your details with appropriate third parties (for example credit reference agencies, such as Experian) before we send you promotions for our financial services products, to ensure your information is accurate and fulfils our legal and regulatory obligations, and to tailor those offers to you. Rest assured that all applications for financial services products will be assessed on a case-by-case basis.

14. Contact Us or the Regulator

If you have any further questions about this Privacy Policy you can contact our Group Data Protection Officer. If you have any questions about this Privacy Policy or relating to our use of your information, write to us at

IMAGINEX. Villa 263, El-Tess’en Street. 2nd District, 5th Settlement, New Cairo, Egypt or email info@justimaginex.com

We hope to resolve any privacy concerns you may have.

If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to any supervisory authority or other public body with responsibility for enforcing privacy laws. In the UK, the UK Information Commissioner’s Office regulates and enforces data protection law. Their procedures can be found at www.ico.org.uk

15. If you live outside the United Kingdom

For all non-UK customers

By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.

Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.

By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.

This may occur because our information technology storage facilities and servers are located outside your country of residence.

We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.

We’ll ensure that any third parties process your personal data only in accordance with their legitimate interests.

These third parties may be subject to different laws from those which apply in your country of residence.

Please note that we do not take active steps to ensure that any overseas recipient of your personal data complies with the laws which apply in your country.