Privacy Notice
Privacy Notice IHinternational.com
January 2023
We have done our best to write this notice (the or this “Privacy Notice”) in simple terms. To facilitate your understanding of this Privacy Notice, it consists of two layers with an introductory summary of its content.
1. Introduction
In this Privacy Notice, a reference to “IHIA” shall be a reference to IH International Advisors Ltd. (which, for the avoidance of doubt shall not include any of its affiliated entities including IH International Advisors US, Inc. (“IHIA US")). This Privacy Notice describes IHIA’s policies and practices regarding its collection and use of personal data collected from users of the Website, and sets forth such users’ privacy rights in respect of the same. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies. IHIA is the data controller in respect of personal data we collect from you via the Website.
We mainly use your personal data to provide the Website and its services to you or to answer your queries received by email.
As we are part of an international group of companies and share administrative systems, we may share your personal data with affiliates for administrative purposes and as further described below.
You are entitled to review how we process your personal data. For questions or comments about this Privacy Notice and our privacy practices generally, please contact us via: privacy@IHinternational.com.
2. What data we collect and use (process)
We may collect personal data from you when you visit the Website. Broadly personal data this falls into two categories:
Personal data we collect automatically:
IP addresses and cookies
IHIA does not automatically collect personal data about its Website visitors, other than IP addresses and cookies. For more information about cookies, including how to see what cookies have been set and how to manage and delete them, please consult our Cookie Policy.
Personal identifiable data
Infrastructure / WaaS: In our infrastructure IP numbers are stored in infrastructure components that manage traffic and security (load balancing and web application firewall) in Azure region West Europe. The purpose of storage is to manage traffic efficiently and to avoid and manage security risks, threats and abuse. IP numbers are never stored together with other personal identifiable information.
Personal data you submit to us:
Correspondence contact details
If you correspond with us, we may retain such correspondence and the information contained in it (such as name, e-mail, contact information, occupation and, any personal identifiable information you provide in free text form).
Recruitment:
If you transmit personal data to us (including via the website or any email address contained on it) in connection with an application for employment, we will process that personal data in accordance with the IHIA Job Applicant Privacy Notice.
3. Why we use your personal data
We process your personal data for the following purposes:
Smooth Website functioning
When you view the Website or any other site linked from this Website, we may store some information on your computer in the form of a “cookie”, which enables us to better tailor the Website and allows you to navigate on the Website.
Legal basis: We process your personal data because it is of our legitimate interest to provide you with the Website, and we ask for your consent to place cookies on your device.
We process your IP address, to help diagnose problems with our server and to administer our Website. IP numbers are stored in infrastructure components that manage traffic and security (load balancing and web application firewall).
Legal basis: Processing is necessary for the performance of a contract to which the Website visitor is party or in order to take steps at the request of the Website visitor prior to entering into a contract (when we provide you with the Website or requested materials). IP numbers are never stored together with other personal identifiable information.
Answering Correspondence with you
If you contacted us by email, the postal service, or other form of communication, you might be providing us with, as the case may be, your name, e-mail, contact information, occupation and, any personal identifiable information you provide in free text form in order to respond to your inquiry during a certain period as prescribed in the applicable legislation.
If you wish to have IHIA “erase” your personal information or otherwise refrain from communicating with you, please contact us at privacy@IHinternational.com.
Note: if you ask IHIA to refrain from contacting you by email at a certain email address, IHIA will retain a copy of that email address on its “master do not send” list in order to comply with your no-contact request.
Legal basis: Processing is necessary for the purposes of the legitimate interests pursued by IHIA in answering queries, since such interests are not overridden by the interests or fundamental rights and freedoms of the correspondents.
Compliance with legal obligations
We may use your personal data to complete our contractual obligations and to comply with our legal obligations when to do so is required by applicable law, regulation or court order.
Legal basis: Processing for the purpose of complying with our legal obligations is based on the mandatory legal framework applicable to us.
4. When and how we share information with others
With our affiliates to provide you with the services
For the purpose of providing you with the services about our affiliates or subsidiaries we may disclose personal information that you provide via the Website to our affiliates (i.e. IHIA US and other companies within the Interogo Holding Group) that are entrusted to process your information on our behalf in accordance with our instructions, this Privacy Policy and other appropriate measures for privacy and security.
With third parties when it is necessary pursuant to contractual or regulatory obligations
Our ambition is to only share your personal information with others when it is necessary. Such situations may include necessity for the completion of a contract with a third party, or when we have acceptable business reasons to do so (e.g. suppliers of IT services (such as cloud service providers or the Website provider) or suppliers of IHIA’s CRM system).
We do not sell personal information to anyone and only share it with third parties who are facilitating the answering of your queries or the delivery of services relating to the Website.
We may also disclose your personal information to third parties if we have good reasons to believe that access, use, retention or disclosure of such information is reasonably necessary to:
- comply with any court order or other legal obligation;
- enforce or apply our terms of use and other agreements; and
- protect the rights, property, or safety of any Group Person
This includes exchanging information with other companies and organizations for the purposes of fraud protection.
5. Transferring personal data abroad
IHIA has its headquarters in the United Kingdom. Information we collect from you may be processed within the EU and in Switzerland. Additionally, any transfer to IHIA US, would involve a transfer to the United States of America.
IHIA endeavours to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistently with your relationship with IHIA and the practices described in this Privacy Notice. Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or via any link or email address set out thereon. Any transmission of personal information is at your own risk. We also minimize the risk to your rights and freedoms by not collecting or storing sensitive information about you.
If we were to transfer your personal data to third countries (for example, in respect of a transfer to IHIA US), i.e. countries outside the UK/EU/EEA, we will enter into the appropriate agreements and take other measures in accordance with applicable legal requirements.
6. Data subject rights
The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects. This Privacy Notice is intended to provide you with information about what personal data IHIA collects about you and how it is used. If you have any questions, please contact us at privacy@IHinternational.com.
If you wish to confirm that IHIA is processing your personal data, or to have access to the personal data IHIA may have about you, please contact us at privacy@IHinternational.com. You may also at any time write to “FAO: The Personal Data Protection Champions, IH International Advisors Ltd., Floor 4, 60 Charlotte Street, London, W1T 2NU, United Kingdom.
You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside IHIA might have received the data from IHIA; what the source of the information was (if you didn’t provide it directly to IHIA); and how long it will be stored. You have a right to update or correct (rectify) the record of your personal data maintained by IHIA if it is inaccurate. You may request that IHIA erase that data or cease processing it, subject to certain exceptions. IHIA does not use your data for direct marketing purposes.
In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how IHIA processes your personal data. When technically feasible, IHIA will—at your request—provide your personal data to you or transmit it directly to another controller.
Reasonable access to your personal data will be provided to you at no cost upon request made to IHIA at privacy@IHinternational.com. If access cannot be provided within a reasonable time frame, IHIA will give you with a date when the information will be supplied. If for some reason access is denied, IHIA will provide an explanation as to why access has been denied.
7. Security of your information
To help protect the privacy of data and personally identifiable information you transmit through use of this Website, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information.
8. Data storage and retention
Location of your data
Your personal data is stored by IHIA on its servers, and on the servers of the cloud-based database management services IHIA engages, located in Switzerland.
Retention times
We only retain your data for the time reasonably needed to complete the purposes described in this Privacy Notice.
In case IHIA is contacted at privacy@IHinternational.com or info@IHinternational.com and otherwise through the associated contact details for general queries, it retains correspondence including personal data, such as email address, place of work etc., for the time necessary to provide a satisfactory reply and for a reasonable term thereafter as prescribed in the applicable legislation.
In order to provide journalists with a good experience, we may elect to involve the Media Team of our affiliate, Interogo Holding AG and in such circumstances, they may retain correspondence with us which may include personal data, such as email address, place of work etc., for the duration of the business relationship the journalist and for a reasonable term thereafter as prescribed in the applicable legislation.
For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact IHIA at privacy@IHinternational.com.
Review
We continuously review and update our retention periods for personal data to ensure that we do not keep data for longer than necessary.
9. Changes and updates to the Privacy Notice
Updates to this Notice
As our organization, services and website change from time to time, this Privacy Notice and Website Terms may change as well. We reserve the right to amend the Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice on the Website. You should check the Website frequently to see the current Privacy Notice that is in effect and any changes that may have been made to it.
Significant changes to this Privacy Notice
If we make any change in the way we collect, use or share personal data, we will make a note of the update under the section “Change history” below.
10. Questions, concerns or complaints
To ask questions or comment about our Privacy Notice or our privacy practices, contact us via: privacy@IHinternational.com.