Data controller and data privacy manager
We have appointed a data privacy manager to oversee compliance with this privacy notice: Tupac Ferreira.
How to contact us
All such communications are examined and replies issued where appropriate as soon as possible. If you are unsatisfied with the reply received, you may refer your complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, or to the relevant regulator in your jurisdiction.
Information that we collect
We collect different types of information:
Non-personal Information: information in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose.
If we combine non-personal information with personal information the combined data will be treated as personal information for as long as it remains combined.
We treat information collected by cookies and other technologies as non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal data by local law, we also treat these identifiers as personal information.
How we collect data
We collect data in three basic ways:
Information you provide us which we need in order to provide you with our services and products. We request you to provide us with certain information in order to provide the products and services that you have chosen (e.g. when you send us a request or register to receive our email newsletter, we request your name and email address). You are not required to provide the information that we request, but, if you chose not to do so, we may not be able to provide you with our services or respond to your queries.
Information we collect through your use of our products. We collect information that helps us to deliver the service you have chosen and to improve your experience, when you use our Website and interact with it (e.g. we automatically collect details about the device you are using, including its IP address, its device ID, the browser you are using, the operating system that the device use, the email provider, the location (in some cases), the pages you read on our Website and how you got to them). This is done through cookies and other technologies.
Information we receive from third parties. We receive occasionally information from third parties with whom we work with. These parties provide additional information that you have shared with them (e.g. your interaction on our sites) to help us personalise our services to you.
Information we do not track. We do not track or collect any sensitive information about you. This includes race, religion, ethnicity, and political opinion.
Personal information that we collect when you send us requests
The following are the types of personal information we collect when you send us requests:
When you contact us, using the contact form on our Website, we collect your name and email address. We will also record details of the query or request and how it is dealt with on our systems.
When we collect your email address we will record your preferences regarding receipt of marketing emails from us in relation to our own products and services and those of third parties.
When you register to receive our email newsletter, we collect your name and email address.
Personal information that we collect through cookies and other technologies
Our Website, email messages and advertisements use various technologies to collect and store information, including “cookies”, pixel tags, web beacons and other technology that identify your browser or device.
We and our partners use these technologies to help us better understand user behaviour, tell us which parts of our Website people have visited, improve user experience and the overall quality of our Website, and facilitate and measure the effectiveness of advertisements and web searches.
This information includes:
Cookies and other technologies track users' activity through our Website, like the date and time that you visit, what pages you visit, how long you stay on the pages, where you have clicked on a page, and details of any crashes or system bugs you might encounter, how you arrived on our website (e.g. from a search engine, or by clicking on one of our adverts). We use the gathered information to e.g. improve our Website, offer interactive features, recall specific information during subsequent visits to our Website.
Cookies and other technologies control the number of times you see a given ad in mobile advertising services, deliver ads that relate to your interests, and measure the effectiveness of ad campaigns;
Cookies and other technologies remember personal information when you use our Website, and this enables us to make your experience more convenient and tailored.
Pixel tags enable us to know when an email has been opened or accessed. We may use this information to reduce or eliminate messages sent to users.
We may use a “click-through URL” linked to our content in some of our email messages, and we track this click-through data to help us determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked by “click-through URL”, you should not click text or graphic links in the email messages.
We gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to understand and analyse trends, to administer the Website, to learn about user behaviour on the Website, and to improve our Website. We may use this information in our marketing and advertising services.
If you want to disable cookies, check with your browser provider to find out how to disable cookies. Please note that certain features of our Website will not be available once cookies are disabled.
Personal information that we receive from third parties
We sometimes use additional information such as telephone numbers or postcodes from third parties (like list brokers, researchers or telemarketing agents, who have gathered this information lawfully) to help us to contact you or to help us make marketing decisions. This includes advertising (by ourselves or via advertising partners) to groups of people with particular interests. These third parties may give us access to your personal information, if you have allowed them to do so.
We may also work with third parties to identify individuals who may be interested in our products and services or in some cases our sponsors / advertisers’ products and services. These third parties may give us access to your personal information, if you have allowed them to do so. In any communication you receive from us, through these third parties, we make sure to identify ourselves (and them) so that you know who has access to your information.
Use of personal information
We primarily use your information for the purpose of delivering the products and services that you have chosen and to personalise our interactions (including advertising) with you.
When providing products and services, we need to use your information in certain ways to provide our products or services to you, in accordance with our contracts with you. In this case, even if you have not given us express consent to use your personal information, it is lawful and necessary for us to use your information so that we can deliver the products or services you have chosen. We may use your personal information to:
Manage customer service queries, obtain, respond to and manage feedback from you;
Fulfill your orders and contracts with us;
Manage your privacy preferences and to ensure you only receive communications that you have requested, which may include using your details to suppress you from communications;
Send important notices, from time to time, such as communications about service changes and changes to our polices or new polices;
We need your consent to use your personal information for some specific purposes such as marketing, brand response communications and personalised advertising. Ways in which we will use your personal information if you consent are as follows:
We may use your information to provide general location-based services (e.g. the region or country you are in), advertising or search results for our content. You may withdraw consent at any time by not using the location-based features and turning off the location services settings on your device and computer.
We may send marketing communications via a range of channels including email and you can opt out of these at any time. If you give us marketing permission, we may contact you to tell you about special offers or IMPOSSIBLE’s products or services.
We may pass your information to specially selected third parties who would like to contact you with information regarding their own products and services. Those parties are responsible for their use of your data and you should read their privacy policies carefully.
We will ask you if you wish to opt-out of such marketing when you first sign up to receive our products or services. You can also update your preferences at any time by contacting us. You can also opt out of email marketing by clicking the unsubscribe link at the bottom of our emails. This does not apply where we have some other legal basis for contacting you.
In order to deliver advertising and marketing messages that are relevant to you, we may use the information we hold about you, including details that we collate from your use of our services or third parties, such as more precise information on your location, to ensure that the advertising you see is of interest to you.
In certain cases, even if you have not given us express consent to use your personal information, it is lawful for us to use your information where necessary to further our legitimate interests, where those legitimate interests are not overridden by your rights or interests:
To help us create, develop, operate, deliver, maintain, protect and improve our Website to develop new Website.
To help us improve our customer and user experience.
To measure customer and user response and engagement with our products and services such as email newsletters. This may include sharing your information with third parties who help us to analyse and measure these things.
To ensure our Website is compatible with the browsers and operating systems used by most of our visitors.
To create audience profiles for personalised advertising, marketing or research and development on and off our Website. To enable us to personalise the content and advertising you see (including on social media), we may use your interaction and browsing behaviour or preferences (such as how and what you read on our Website) to create audience profiles. This is to enable content and message personalisation, and in some cases, advertising to be delivered to you or a group of users (an audience) with similar interests to you. This can be done both on our Website and on those of third parties. We may analyse your individual information to create a profile of your interests and preferences as a part of an audience. These insights are used to help us make marketing decisions so that we can ensure our messages are relevant to you. There are times we may use additional information available from external sources to help us do this effectively. You can choose to opt out of our audience profiling activity if you wish. This does not mean that you will no longer see advertisements, it just means that the advertisements you will see are no longer personalised to your interests. Please contact us to do so.
To detect and reduce fraudulent activity and for other security related purposes such as to help us protect against crime or other security issues.
For any purpose required by law or regulation and to verify information that we provide to third parties for compliance and audit purposes. We may share your personal data with a third-party auditing organisation so they can verify aggregated statistics about circulation and usage of our products or review our policies, processes and procedures for compliance with relevant standards.
You have the right to object to any of the above uses of your information, please contact us if you wish to do so. We will consider all objections reasonably, but there may be legal reasons where we deem that the use of your information is still appropriate. We will explain our decision to you in a timely manner.
Information that we share
In some instances, we disclose personal information to third parties when it is necessary to deliver a service or product, or to help us improve your experience with us, or when we are required to do so by contract or law.
“Third parties” include companies within the IMPOSSIBLE Group, agents, subcontractors and other third parties, for example in the context of the possible sale or restructuring of the business.
We have in place contracts to ensure the information remains secure and limited in use, and if we do not have a legitimate business reason to pass on your information, we will ask you to give consent first.
Some examples of when we share your information are below:
Disclosure to Third Parties: At times we may make certain personal information available to strategic partners that work with us to provide Website, or that help us market to customers. We will only share personal information to provide or improve our Website and advertising. Personal information will only be shared with third parties for their marketing purposes if you give explicit permission for us to do so.
Disclosure to Service Providers: We share personal information with hosting providers, customer relationship management, technology providers, consultants, auditors, and other companies who provide services such as information processing, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our Website, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever IMPOSSIBLE operates.
Mandatory Disclosures: It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for IMPOSSIBLE to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
Other Disclosures: We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
Storing and transferring personal information internationally
We have studios around the world, so the personal information we collect from you may be passed to our colleagues that are based abroad, including outside of the European Economic Area (EEA).
We may also transfer internationally aggregate information on the usage of our Website to third parties across the globe with whom we work with, but this will not include information that can be used to identify you.
If we transfer your personal data outside of the EEA please rest assured that we will ensure that appropriate measures are in place to protect your personal data and to comply with our obligations under applicable data protection law.
By using our products and services you acknowledge and agree to your personal information being transferred in this way, including to jurisdictions outside EEA.
We have in place measures to protect us and you from unauthorised access to or unauthorised alteration, disclosure or destruction of information that we collect online:
We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
We restrict access to personal information to our employees, contractors and agents who need to know that information in order to process it for us and who are subject to statutory or contractual confidentiality obligations.
Please remember, however, that no Internet, email or mobile transmission is ever fully secure or error free. Most email and mobile transmissions are not encrypted, so you should take special care in deciding what information you send to us via email, SMS or text message, or other mobile transmission.
We do not knowingly collect, use or disclose personal information from children under the minimum age in the relevant jurisdiction, without verifiable parental consent. If we learn that we have collected the personal information of a child under the minimum age on the relevant jurisdiction, without first receiving verifiable parental consent we will take steps to delete the information as soon as possible.
Important Information about Consent
When we process your personal data on the basis of your consent, you are free to withdraw that consent at any time. You can withdraw your consent by contacting us using the contact details at the bottom of this notice. If your consent relates to receiving email marketing you can use the unsubscribe link in the email. Please note that if you withdraw your consent we may not be able to continue to provide the related service to you.
Accessing and updating Personal Information
You have various rights under data protection law in connection with our processing of your personal data:
Right to access your personal data - You have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
Right to rectification – You have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information so that it is complete.
Right to erasure – You have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.
Right to restriction of processing or to object to processing – You have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
Right to data portability – You have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format.
Retention of Personal Information
We will retain your personal information in accordance with our record retention policy. The record retention policy operates on the principle that we keep personal data for no longer than is necessary for the purpose for which we collected it, and in accordance with any requirements that are imposed on us by law. This means that the retention period for your personal data will vary depending on the type of personal data. As we only collect personal data for defined purposes, we assess how long we need to keep personal data for in order to meet our reasonable business purposes. We review our retention periods for personal information regularly.
If you have not interacted with us in any way, we will generally no longer hold your information after 3 years (although this may be shorter for individual businesses (you can confirm by contacting us)). Sometimes we may need to keep it for longer periods such as tax and other financial regulatory reasons. We would only keep it for longer than this if we are required to by law.
If you request for us to no longer contact you, for example with marketing communications, we will retain the minimum amount of information about you so that we can ensure we remove you from any future communications. Please note that if you ask us to completely remove all information about you, and you subsequently use our products and services at a later date, we will no longer be able to recognise your previous request to not be contacted, which is why we would keep it and suppress it in line with industry standards.