- “Comply with a legal or regulatory obligation” means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- “Data” means personal and non-personal User’s data that is submitted, generated, featured and displayed through the Platform, collected from the use of the Service and stored on Invygo’s servers.
- “Legitimate Interest” means the interest of our business in conducting and managing our Services to enable us to give you the best Service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- “Invygo’s Terms and Conditions” means all of the terms, conditions and notices contained or referenced in Invygo’s Client Terms and Conditions and Vendor Term and Conditions and all other Invygo rules, policies (as amended from time to time) available on the Platform.
- “Performance of our Services” means processing your Data where it is necessary for the performance of our Services.
- “User”, “you” or “your” collectively mean the person, company, or organization that uses and/or visits our Platform and/or the Service. A User may be a Client, a Vendor, both, or neither.
- 1.Important information and who we are
Our Platform is not intended for children and we do not knowingly collect data relating to children.
Please note that it is substantial that the Personal Data we hold about you is accurate and current. Please keep us informed and updated if your Personal Data changes during your relationship with us.
- 1.3 Third-party links
- 2.The data we collect about you
- 2.1 What Is Personal Information?
2.1.2“Personal information” or “Personal Data” collectively mean information that specifically identifies an individual (such as a name, address, telephone number, mobile number, e-mail address, birthday, office location, professional and personal interests, company name, title department, spoken languages) or information about that individual that is directly linked to personally identifiable information.
2.1.3Depending on which of our Services you use and how you interact with our Platform, we collect different kinds of information from or about you. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together follows:
- Identity Data includes first name, last name, address, username or similar identifier, title, date of birth and gender.
- Contact Data includes billing address, delivery address, location, email address and/or telephone numbers.
- Payment Data includes bank account and payment card details, payment history.
- Transaction Data includes details about payments to and from you and other details of the Vendor Services you have purchased through our Platform.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, make and model (mobile phones only), operating system, hardware version, platform, device settings and other technology identification on the devices used to access our Platform, file and software names and types, device identifiers, time zone setting and location, device locations such as through GPS, Bluetooth or WiFi signals, browser plug-in types and versions, operating system and platform, connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
- Profile Data includes any Vendor Profile information, any User’s username and password, any purchases or orders made by a Client, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our Platform, products and services and how you use your devices to access our Platform, including the screens you visit and searches you make.
- Special Categories of Personal Data includes details about your race or ethnicity or religion.
- Marketing and Communications Data includes your preferences in receiving marketing from us andour third parties and your communication preferences
- Other Data includes:
- photos or other data uploaded onto any of our Platform by you or shared with other Users of our Platform by you via our Platform;
- communications with us via social media platforms, email, electronic messages and other electronic and non-electronic communications;
- third party partner information related to how you use our third party partners, such as your reviews of our merchant partners or other service providers.
- your networks and connections made available to us, depending on the permissions you have granted, from your mobile and desktop devices' address book contacts, and other social media such as Facebook, Instagram, Pinterest and Twitter.
2.1.5 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
- 2.2 What Personal Information Do We Collect?
2.2.1 Personal Information You Provide Us with: We receive and store any information you enter on our Platform or that you provide us with in any other way. The types of Personal Information collected may include your name, address, telephone number, mobile number, e-mail address, birthday, office location, professional and personal interests, company name, title department, spoken languages, use information regarding your use of our Service and Platform, and browser information.
The Personal Information you provide is used for such purposes as allowing you to set up an Account and/or complete a Vender Profile that can be used to interact with other Users through the Platform, improving the content of the Service, customizing the advertising and content you see, and communicating with you about events and new features. We may also draw upon this Personal Information in order to adapt the Services of our community to your needs, to research the effectiveness of our network and Services, and to develop new tools for the community.
2.2.3 Information Collected Automatically: When you use the Service, Invygo automatically receives and records information on our server logs from your browser or mobile platform, including your location, IP address, cookie information, and the page you requested. We treat this data as non-Personal Information, except where we are required to do otherwise under applicable law. Invygo only uses this Data in aggregate form. We may provide aggregate information to our partners about how our customers, collectively, use our site, so that our partners may also understand how often people use their services and our Service.
2.2.4 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 and you fail to provide that Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). In this case, we may have to cancel the Service which you have with us, provided that we will notify you if this is the case at the time.
- 3. How is your Personal Data collected?
We use different methods to collect Data from and about you including through:
- From the information you provide to us when you meet us;
- From information you provided to us by your company;
- When you communicate with us in writing, by telephone, fax, email or through the Platform or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
- When you complete (or we complete on your behalf) Vendor application or other forms;
- When you register an Account with our Platform;
- From publicly available sources or from third parties, most commonly where we need to conduct background checks about you;
- Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, and email or otherwise. This includes Personal Data you provide when you:
- apply for our Services;
- create an Account on our Platform;
- subscribe to our Service or publications;
- enter a competition, promotion or survey; or
- entering data for installing or using any Invygo powered application and/or installing or using our App;
- correspond with us (online or offline including via email addresses and phone numbers), if you contact us;
- post Content on our Platform; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out above Technical Data from the following parties:
- analytics providers such as Google;
- advertising networks/agencies and
- search information providers.
- Contact, Financial and Transaction Data from technical and payment providers;and
- Identity and Contact Data from publicly available sources.
- 4. How do we share your information?
4.1 Information shared with everyone in the community:If you are a Vendor, we may publicly share some of your Vendor Profile such as your contact person name, photo and contact details, office location, Vendor Services, company name and logo, your event photos, and any other information that you allow us to share. You can choose what Personal Information you provide as part of your Vendor Profile. We recommend that you guard your sensitive information.
4.2 Information shared with Vendors: As a Client, if you request for a Vendor Service, and/or make a booking via the Platform, we may share your name, phone number, location and email address with the applicable Vendor in order to fulfill your request or booking, as applicable.
4.3 Partners: In addition to the data sharing described above, we enter into relationships with a variety of businesses and work closely with them. In certain situations, these businesses sell items or provide promotions to you through Invygo’ Service. In other situations, Invygo provides Services or sells products jointly with these businesses.
4.5 Protection of Invygo and Others: We may release Personal Information when we believe in good faith that release is necessary to comply with the law, including laws outside your country of residence; enforce or apply our Terms and Conditions and other agreements; or protect the rights, property, or safety of Invygo, our employees, our users, or others. This includes exchanging information with other companies and organizations (including outside of your country of residence) for fraud protection and credit risk reduction.
4.6 Credit and debt card and personally identifiable information: This information will not be stored with, sold, shared, rented or leased to any third parties. Invygo will not pass any debit/credit card details to third parties.
- 5. How we use your Personal Data
5.1 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:
- Where we need to perform our Service
- 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.
- Where we need to comply with a legal or regulatory obligation.
5.2 Generally, we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
5.3 Purposes for which we will use your Personal Data5.3.1 Performance of our Services
We process your Personal Data because it is necessary for the performance of our Services In this respect, we use your Personal Data for the following:
- To assist with preparation of a Confirmation Order for you regarding the Vendor Services Vendors offer;
- To deal with any complaints or feedback you may have;
- For any other purpose for which you provide us with your Personal Data.
In this respect, we may share your Personal Data with or transfer it to the following:
- Subject to your consent, third parties whom we engage to assist in delivering the Services and Vendor Services to you, including Vendors and other third parties;
- Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
- Debt collection agencies where it is necessary to recover the money you owe us;
- Credit scoring agencies where it is necessary in the performance of our Services;
- Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you;
- Our data storage providers:
- Your agents, advisers, intermediaries, and custodians of your assets who you tell us about.
We also process your Personal Data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person. In this respect, we use your Personal Data for:
- For the administration and management of our business, including recovering the money you may owe to us, and archiving or statistical analysis;
- Seeking advice on our rights and obligations, such as where we require legal advice. In this respect, we will share your Personal Data with our advisers or agents where it is necessary for us to obtain their advice or assistance and with third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.
We also process your Personal Data for our compliance with a legal obligation which we are under. In this respect, we will use your Personal Data for the following:
- To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws;
- As required by tax authorities or any competent court or legal authority. In this respect, we will share your Personal Data with the following:
- Our advisers where it is necessary for us to obtain their advice or assistance;
- Our auditors where it is necessary as part of their auditing functions;
- With third parties who assist us in conducting background checks;
- With relevant regulators or law enforcement agencies where we are required to do so.
- We may send you marketing about the Services we provide which may be of interest to you, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you or in order to update you with information (such as legal or commercial news) which we believe may be relevant to you. We may communicate this to you in a number of ways including by post, telephone, email or other digital channels.
- We may use your Identity, Contact, Technical, Usage 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 (Marketing).You may receive marketing communications from us if you have requested information from us or purchased services from us [or if you provided us with your details in case registered for a promotion] and, in each case, you have not opted out of receiving that marketing.
- We will get your express opt-in consent before we share your Personal Data with any company outside Invygo for marketing purposes.
- You can ask us or third parties to stop sending you marketing messages at any time by logging into the Platform and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
- 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. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 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. Data Security
6.1We have put in place appropriate security measures (software/hardware) to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized 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. Owever, Invygo Cannot guarantee the security of any information that is disclosed online.
6.2 We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- 7. Data retention
- 7.1 How long will we use your Personal Data?
We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorized 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 requirements. In some circumstances, we may anonymize 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. If you wish to exercise any of the rights set out above, please contact us.
- 8. 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, if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- 9. What may we need from you?
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
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