Privacy Policy

BACKGROUND:

IME London understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, http://www.imelondon.co.uk31T (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner, that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1.    Definitions and Interpretation 
    In this Policy, the following terms shall have the following meanings:  

 “Account”    means an account required to access and/or use certain areas and features of Our Site;
 “Cookie”  means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site  and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section  13, below;
 “Cookie Law”  means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
 “personal data”  means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 amended byEU Regulation  2016/679 – the General Data Protection Regulation (“GDPR”); and
 “We/Us/Our”  means IME London, its subsidiaries in the UK registered in England Authorised and Regulated by the FCA for the  provision of Payment Services; 

   2.    Information About Us
    2.1    Our Site is owned and operated bySubhida Limited.
    2.2    Our Data Protection Officer is Mr. Kamal Paudel and can be contacted by email at kamal@imelondon.co.uk, by telephone on   +44 20 8866 0307 or by post at PEntax House , South harrow , London, HA2 0DU
    2.3    In the UK we are regulated by the Financial Conduct Authority; our subsidiaries are respectively

3.    What Does This Policy Cover?
    This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have  no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4.    Your Rights
    4.1    As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have         been designed to uphold:
        4.1.1    The right to be informed about Our collection and use of personal data;
        4.1.2    The right of access to the personal data We hold about you (see section 12);
        4.1.3    The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us         using the details in section 14);
        4.1.4    The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold             your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner,             please contact Us using the details in section 14);
        4.1.5    The right to restrict (i.e. prevent) the processing of your personal data;
        4.1.6    The right to data portability (obtaining a copy of your personal data to re-use with another service or             organisation);
        4.1.7    The right to object to Us using your personal data for particular purposes; and
        4.1.8    Rights with respect to automated decision making and profiling.
    4.2    If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in         section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to         lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
    4.3    For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens         Advice Bureau.

5.    What Data Do We Collect?
    Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data (please also see     section 13 on Our use of Cookies and similar technologies and Our Cookie Policy
    For detail, please refer to our Data Protection Policy and Privacy Notice.

6.    How Do We Use Your Data?
    6.1    All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which         it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Act 1998         as amended by GDPRat all times. For more details on security see section 7, below.
    6.2    Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a         contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or         because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
        6.2.1    Providing and managing your Account;
        6.2.2    Providing and managing your access to Our Site;
        6.2.3    Personalising and tailoring your experience on Our Site;
        6.2.4    Supplying Our services to you (please note that We require your personal data in order to enter into a contract             with you);
        6.2.5    Personalising and tailoring Our services for you;
        6.2.6    Replying to emails from you;
        6.2.7    Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time;
        6.2.8    Market research;
        6.2.9    Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user             experience;

    6.3    With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include             contacting you with information, news and offers on Our services. We will not, however, send you any unsolicited         marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our         obligations under the     Data Protection Act 1998 as amended by GDPR and the Privacy and Electronic Communications (EC         Directive) Regulations 2003.
    6.4    Third-parties  whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please         refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of         such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third         parties.
    6.5    You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete         it.
    6.6    We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first         collected. Data will therefore be retained for the following periods (or its retention will be determined on the         following bases):
        6.6.1    5 years since the date we concluded our last transaction or ended our relationship with our clients;
        6.6.2    6 months for employment applications
        6.6.3    In an on-going basis for employment purposes, and for 4 years after individuals leave employment.

7.    How and Where Do We Store Your Data?
    7.1    We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for         as long as We have your permission to keep it.
    7.2    Your data will be stored in the UK, unless you request we provide you with off shore services, in which case your         information will be shared with our Custodians outside the EEA (Please refer to our Privacy Notice for links to our         Custodians Privacy Policy and information on how the process personal data).

    You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the     EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK     and under the Data Protection Act 1998 and GDPRincluding:
        7.2.1    Organising Data Processing control arrangements with our Custodians
    7.3    Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure         data collected through Our Site.
    7.4    Steps We take to secure and protect your data include: 
        7.4.1    Appointment of a Data Protection Officer
        7.4.2    Implementation of a Data Management Framework, including policies, procedures and internal control mechanisms to             ensure your data is secure and processed according to your rights.

8.    Do We Share Your Data?
    8.1    In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal         data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court         order, or a governmental authority.
    8.2    We may sometimes contract with third parties -such as Custodians to provide services to you on Our behalf. These may         include payment processing, order processing and fulfilment of your instructions. In some cases, the third parties may         require access to some or all of your data. Where any of your data is required for such a purpose, We will take all         reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our         obligations, and the obligations of the third party under the law.
    8.3    We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and         other information. All such data will be anonymised and will not include any personally identifying data, or any         anonymised data that can be combined with other data and used to identify you. We may from time to time share such data         with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and         used within the bounds of the law.
    8.4    The third party data processors used by Us and listed in our Privacy Notice are located in the UK; we also may sometimes         use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of         all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We         will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK         and under the Data Protection Act 1998 and GDPR
    8.5    In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal         data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court         order, or a governmental authority.

9.    What Happens If Our Business Changes Hands?
    9.1    We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of         all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our         business that is being transferred, be transferred along with that part and the new owner or newly controlling party         will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was         originally collected by Us.
    9.2    In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed         of the changes. When contacted you will, however, be given the choice to have your data deleted or withheld from the new         owner or controller.

10.    How Can You Control Your Data?
    10.1    In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be         given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your         data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by         unsubscribing using the links provided in Our emailsandat the point of providing your detailsand by managing your         Account).
    10.2    You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference  Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the  MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not         prevent you from receiving marketing communications that you have consented to receiving.

11.    Your Right to Withhold Information
    11.1    You may access certain areas ofOur Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
11.2    You may restrict Our use of Cookies. For more information, see section 13.

12.    How Can You Access Your Data?
    You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee     is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more     details at kamal@imelondon.co.uk, or using the contact details below in section 14. Alternatively, please refer to Our Data     Protection Policy.

13.    Our Use of Cookies
    13.1    Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those         placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and         to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your         privacy and personal data is protected and respected at all times.
    13.2    By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are         those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for marketing         and performance purposes. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies         are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing         consent to them.
    13.3    All Cookies used by and on Our Site are used in accordance with current Cookie Law.
    13.4    Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those         Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience         and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site         may not function fully or as intended. 
    13.5    The following first party Cookies may be placed on your computer or device:

Name of cookie Purpose Strictly Necessary
userid save login preference yes
useremail save login id yes


    13.6    Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to         collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn,         enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies,         however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to         continually improve Our Site, making it a better and more useful experience for you.
    13.7    The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
    13.8    The analytics service(s) used by Our Site use(s) the following Cookies:

Name of cookie Expiration Time Provider Purpose
_ga 2 Years Google used to distinguish users
_gid 24 Hrs Google used to distinguish users
_gat 1 minute Google Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.
AMP_TOKEN 30 seconds to 1 Year Google Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.
_gac<property-id> 90 days Google Contains campaign related information for the user.

    13.9    In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most         internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By         default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help         menu in your internet browser or the documentation that came with your device.
    13.10    You can choose to delete Cookies on your computer or device at any time, however you may lose any information that         enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation         settings.
    13.11    It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and         guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are         unsure about adjusting your privacy settings.


14.    Contacting Us
    If you have any questions about Our Site or this Privacy Policy, please contact Us by email at kamal@imelondon.co.uk, by     telephone on +44 (0) 20 8866 0307, or by post at333 Rayners Ln, Pinner HA5 5EN, UK. Please ensure that your query is clear,     particularly if it is a request for information about the data We hold about you (as under section 12, above).

15.    Changes to Our Privacy Policy
    We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on         Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the     alterations. We recommend that you check this page regularly to keep up-to-date.