1. What is personal data/personal information?
Personal data is information that can be used to directly or indirectly identify you. Personal data also includes anonymous data that is linked to information that can be used to directly or indirectly identify you. Personal data does not include data that has been irreversibly anonymized or aggregated so that it can no longer enable us, whether in combination with other information or otherwise, to identify you.
2. How and when we collect personal data about you
We collect and process personal information when you:
- visit our website and use our app (including when registering on our site, leaving any reviews or comments, or filling in forms such as when you sign up for newsletters or enter a competition);
- create a INMO account, purchase and/or activate any products or services from our website and/or app, download a software update, or subscribe to any of our services;
- contact our customer service or request information from us in any other way;
- participate in our customer satisfaction surveys or other market research, feedback and survey responses;
- communicate with us via social networking websites, third party apps or similar technologies;
- when you direct third parties to share data with us, for example, your mobile carrier.
3. What personal data we collect
Data you provide:
We and our third-party providers and business partners who enable us to operate our products, services and app, may collect and process the following personal information about you which you provide:
- contact details (such as your name, address, email address, phone number);
- demographic information (such as age and/or other information that may identify you as an individual);
- password, account status, devices registered and other authentication information;
- responses to any customer satisfaction surveys or market research (unless these are provided anonymously);
- transactional information about purchases/redemption of products and services;
- financial and credit card information; and
- your marketing preferences.
Other information – including cookies and similar technologies
When you visit our website and app, purchase and/or activate a product or device, download a software update, or connect to our services, 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. Cookies generally only work with web browsers, but there are similar technologies that are used with apps.
This type of information may include the following:
- type of device you use, your device's unique identifier, serial number or device ID;
- the IP address of your device, your operating system and browser type;
- usage information, product interaction, performance and diagnostic information, crash data, search history, browsing history and location information from the devices which you have purchased or on which you install or access our products or services;
- information about your use of our offerings, for example to distinguish you from other users of our app, to remember your preferences to help us to provide you with a good experience when you use our offerings and also information that allows us to improve them; and
- where available, our products and services may use GPS, your IP address, and other technologies to determine a device's approximate location to allow us to improve our products and services.
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.
- Functionality cookies: These cookies allow the site to remember the choices you make (such as your user name, language, last action and search preferences) and provide enhanced, more personal features.
- Advertising cookies: These cookies are used for advertising, including serving and rendering ads, personalising/targeting ads and measuring the effectiveness of ads.
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.
4. How we use your personal data
We may process your personal information for the following purposes:
- to provide you with the information, products and services you have requested and send you marketing and advertising materials;
- to provide, improve, and develop our products and services;
- to communicate with you including in relation to a purchase or to offer you targeted advertisements and services (including if you enter a contest, or other promotion, we may use the personal data you provide to administer those programs);
- to process your transactions;
- for system administration purposes and for internal operations, including troubleshooting, testing, statistical and survey purposes, data analysis, research, and audits;
- to authenticate your access to our website, app, products and services and to distinguish you from other users (for example to remember your log-in details);
- to monitor your use of our website, app, products and services to improve the user experience and to ensure that content is presented in the most effective manner for you and for your device;
- to conduct marketing analysis to allow us to assess trends and the effectiveness of our advertising and marketing campaigns (including using your personal information to evaluate, analyse or predict certain personal aspects relating to you, such as your preferences, economic situation, interests, and/or location);
- to provide customer support and ensure we provide a good level of customer service;
- to personalize your services and communications where such options are available and you choose to use them;
- to notify you of any changes to our services;
- promote safety and security, such as by monitoring fraud and investigating suspicious or potentially illegal activity or violations of our terms or policies;
- to ensure that our website, app, products and services are safe and secure; and
- to comply with applicable laws and regulations.
If you no longer wish to receive email communications for marketing purposes, please contact us to opt-out or click the unsubscribe link within the email.
5. Legal basis for processing your personal 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 certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.
- Our legitimate business interests: Where it is necessary for us to understand our customers, 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. For example, we will rely on this legal basis when we conduct certain market analysis to understand our customers in sufficient detail so we can create new services and improve the profile of our brand.
- Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased a product from us and we need to use your contact details and payment information in order to process your order and send the product to you.
- 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.
6. Disclosure of personal data
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
We make certain personal data available to strategic partners that work with us to provide our products and services or help us market to customers. Personal data will only be shared by us with these companies in order to provide or improve our products, services, and advertising; it will not be shared with third parties for their own marketing purposes without your prior express consent.
We may disclose your personal information to other third parties in the following cases:
- 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).
7. Data storage and transfer
The personal information that we collect may be transferred to, and stored at, a destination outside the EEA or the US, including countries, which have less strict, or no data protection laws, when compared to those in the EEA or the US. 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. 8. Your rights
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 below.
You may also lodge a complaint with the China’s data protection authority regarding the processing of your personal data 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 below) so that we can investigate, and hopefully resolve, your concerns.
9. Third-party websites and services
10. Data retention
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 anonymized unless a longer retention period is required or permitted by law.
12. Contact us