Privacy Policy

This Privacy Policy sets out how ICM Group uses and protects any information that you give ICM Group when you use this website.

ICM Group is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

ICM Group may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 01/05/2018.

What we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, store and use the following categories of personal data about you:

  • your name;
  • job title;
  • place of employment;
  • contact information including your email address.

How we collect your personal information

We will collect your personal information when you contact us by email, telephone, and through the subscription application on our site, either directly from you or a third party representative which you have appointed.

Legal Basis for processing your personal information

We comply with our obligations under the General Data Protection Regulation by keeping personal data up to date; storing and destroying it securely; not collecting or retaining excessive amounts of data; protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect your personal information.

We will process your personal information in the following lawful circumstances:

  1. Where we need to perform the service we have entered into with you;
  2. Where we need to comply with a legal obligation;
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override these interests;
  4. For marketing purposes once we have obtained your consent.

Do we require your consent

We do not require your consent when processing your personal data when responding to your enquiry received through the “general enquiries” function, email or telephone.

However, in circumstances, we may approach you for your consent to allow us to process your personal data for marketing purposes. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

Your right to withdraw consent

In the circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time by contacting us in writing or emailing us at info@icmgroup.im

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another lawful basis for doing so.

What we do with the information we gather

We require your information to understand your needs and provide you with a better service, and in particular for the following reasons:

  • Internal record keeping;
  • We may use the information to improve our products and services;
  • We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided subject to receiving your consent;
  • We may also use the information to customise the website according to your interests.

Processing of third party personal data

When you supply us with personal data about another individual you must ensure that you have the individual’s agreement:

  • to the supply of the personal information; and
  • for us to use, collect, and disclose that individual’s personal data to provide the services and otherwise in accordance with this policy.

If you fail to provide us with your personal information

If you fail to provide certain types of information when requested, we may not be able to perform the service which you have engaged with us to perform.

Further processing

We will only use your personal information for the purposes which we collect it, unless we reasonably consider that we need to process it for another reason that is compatible with the original purpose.

If we need to process your personal information for an unrelated purpose, we will provide you with a new privacy notice which will explain this new purpose and the legal basis for which your personal data is to be processed.

Please note that we may process your personal information without your knowledge or consent where we are required to do so by law.

How long do we retain your personal data?

We will only retain your personal information for as long as necessary in order to fulfill the purpose for which we have collected it for. Details of retention periods for different aspects of your personal information is confirmed within our Data Retention Policy.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How we use cookies

Please see our dedicated cookies page.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Exercising your rights

Unless subject to an exemption under the General Data Protection Regulation, you have the following rights with respect to your personal information:

  • The right to request a copy of your personal data which we hold about you;
  • The right to object to processing that is likely to cause or is causing damage or distress;
  • The right to prevent processing for direct marketing;
  • The right to object to decisions being taken by automated means;
  • The right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed; and
  • The right to claim compensation for damages caused by a breach of the Act.

You will not have to pay a fee to exercise any of your rights. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may require specific information from you to assist us in confirming your identity and ensure your right to access the information. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it

If you would like to exercise any of your rights please contact Chris Lees, Data Protection Officer, at info@icmgroup.im

You have the right to lodge a complaint to the Isle of Man Information Commissioners’ Office if you believe that we have not complied with the requirements of the General Data Protection Regulation.