Privacy Policy
Last Updated 29 Oct 2024
Table of contents
Inox (a trading name of Roches Noires Ventures Limited, a company registered in England and Wales under company number 13556725 whose registered office is at 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF) is committed to respecting your online privacy and recognises your need for appropriate protection and management of any personally identifiable information you share with us. Inox has established this online privacy notice (“Privacy Notice”) so that you can understand the care with which we intend to treat your Personal Information. Personal Information means any information that may be used to identify an individual, including, but not limited to, a first and last name, a home or other physical address and a personal email address or other home contact information.
For the purposes of the Data Protection Act 2018, the European General Data Protection Regulation (“GDPR”) and the retained EU law version of the GDPR (UK GDPR), generally when Inox carries out functions on behalf of our customers we act as their Data Processor, where Inox determines the use of individuals’ Personal Information, as a prospective, current or former employee as well as when we process information when carrying out our marketing operations, we do so as a Data Controller.
1. When do we collect your Personal Information?
Inox collects data relating to you and your use of the services and Site in order to provide Services and features that are responsive to your needs. Inox collects Personal Information in the following ways:
From you when you register and communicate with us. We collect information from you when you register an account with us, request information, send us emails, or speak with us over the telephone or at an event, conference, or meeting.
From you when you report a repair or maintenance issue through the Services.
From the Site. We may collect information from your mobile device when you provide your information to use via the Site.
From third parties. We may receive information about you from a business partner or client.
Automatically as you use our Site. Information collected automatically may include usage details, email address, IP address and information collected through cookies and other tracking technologies.
2. What Personal Information we collect
Information you give us
We require customers who register to use the services (“Services ”) offered on our Site to give us contact information, such as their name, company name, address, phone number, and e-mail address, and (in the case of paying customers) financial qualification and billing information, such as billing name and address, credit card number, and the number of users within the organisation that will be using the Services. Customers who contact us by telephone, attend an event, conference or meeting will also be asked for contact information as described above. Customers of the Services may use the Site to host data and information that includes Personal Information (“Data”). Where you input Data into the Site that you have collected from your contacts, you are responsible for obtaining any required consent of those data subjects under the UK GDPR and you warrant to us that you have fully complied with any applicable data protection legislation in relation to the information you give us.
Reporting tickets
When a repair or maintenance issue is reported through our platform, the contact information of the person reporting and/or occupier is requested and stored. Contact Information includes name, address, phone number, e-mail address and photos of the issues and other relevant information. It is important to ensure that any photos submitted do not include images of people.
Information we collect about you
We may collect certain information about how you use the Services. This may include your IP address, geographical location, browser type, referral source and similar information. This information may be collected by a third-party website analytics service provider on our behalf and may be collected using cookies.
Information we receive from other sources
This is information we receive about you if you use any of the Site we operate or the other Services we provide. We are working closely with third parties (including for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies).
3. Cookies
Some of our Site pages utilise cookies and other tracking technologies. A cookie is a small text file that may be used, for example, to collect information about Site activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a Web user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the Site. Our use of cookies and other tracking technologies allows us to improve our Site and web experience.
We use a number of different cookies on our Site that are broadly grouped into the following categories:
Essential: These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, or make use of our billing services.
Analytics: We use analytics cookies to help us understand how users engage with our Site. This data is used to deliver customised content to customers whose behaviour indicates that they are interested in a particular subject area.
Retargeting: We collect and use profiling cookies which enable us to identify your device when you move between different websites and applications so that we can serve personalised advertising to you.
Email marketing campaigns published by our Site or Inox may contain tracking facilities within the actual email.
How we use the Personal Information we collect
We may use your Personal Information for purposes including, but not limited to, the following:
To send your contact information along with details and photos relating to the repair or maintenance issue to a third-party contractor pursuant to the data controller’s or owner’s instructions;
To send you promotional materials or communications regarding our content and services or those of our subsidiaries, partners, group companies, or third parties including those that work for us, are a party to any of our webinars, or provide similar products to us and we feel may be of interest to you;
To deliver services, products, or transactions that you have requested;
To improve our Site, including upgrading security measures;
To send you promotional materials or communications regarding our content and services or those of our subsidiaries, partners, group companies, or third parties that are working for us that we feel may be of interest to you;
To evaluate the products and services that we offer and develop new or improved products or services and to better understand Inox’s business environment;
For surveys, competitions, and polls;
To notify you about changes to our Service;
To provide technical support to you; and
To ensure network and information security.
4. Marketing opt-out
We do not use personal data submitted by individuals reporting repairs or maintenance issues via our platform for marketing purposes.
You are entitled to opt-out of marketing communications at any time and free of charge by letting us know on the Contact Us page and filling out the webform.
5. What legal bases do we have for processing your Personal Information?
We will collect and process your Personal Information only when one of the following applies:
It is necessary for a legitimate interest (which is not overridden by your privacy interests), such as preventing fraud, improving our Site, to make suggestions to you about other Services or products available through our Site or that of our subsidiaries, partners, group companies or third parties including those that work for us, are a party to any of our webinars, or provide similar products to us and increasing the security of our Services;
You have expressly consented to the collection and processing for a specific purpose such as actioning a repair or maintenance issue or marketing;
It is necessary to fulfil our contractual obligations; or
It is necessary to comply with a legal obligation.
Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. If you wish to withdraw your consent, please let us know on the Contact Us page and filling out the webform.
6. Image Rights
Although photos that are uploaded by you remain your intellectual property, so that Inox can provide the Service to you, you hereby give us the right (an irrevocable worldwide royalty free licence) to host, store, modify, reproduce, communicate, publish and distribute those photos only to the extent permitted by this Privacy Notice. By uploading any photo you confirm that you have the right or necessary consent to send that photo to us and for us to use it in the ways outlined in this Privacy Notice. We have the right to limit the size and nature of any photos that are uploaded and forward them as necessary to a third party contractor for a repair or maintenance issue through the Service.
All information other than photos that you submit will become our intellectual property but can only be used to the extent permitted by this Privacy Notice.
7. Disclosure of your Personal Information
Inox will not sell, trade, or share your Personal Information, except in the circumstances outlined below:
Any third party contractor who has been instructed to manage a repair or maintenance issue on your property agents or owner’s instructions;
Any member of our group, which means any subsidiaries, ultimate holding company and its subsidiaries;
Business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you, which can include (but is not limited to) those suppliers listed below in Annex 1;
Analytics and search engine providers that assist us in the improvement and optimisation of our Site;
Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
Where we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our terms of use, or to protect the rights, property or safety of Inox, our customers, or others;
In the event that we sell or buy any business or assets, in which case we will disclose your Personal Information to the prospective seller or buyer of such business or assets.
8. Security of your Personal Information and international data transfers
In accordance with the applicable laws and regulations, we have taken adequate technical and organisational measures to safeguard the security of your personal information. We store the personal information that we process on a secure database that is protected by technical access controls. We periodically 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 employees, third parties and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
Please be advised that while we strive to protect your personally identifiable data, we make no guarantees or assurances about our ability to prevent any such loss, access, or misuse and are not responsible in the event that such loss or misuse occurs.
We may transfer your personal data outside the European Economic Area (EEA) in our performance of Services.
Whenever we transfer your personal data out of the EEA, we ensure an appropriate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK;
Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK;
Where we use providers based in the USA, we carry out due diligence before and during any continued involvement and will check the service providers we are presently using have signed up to the EU-U.S. and Swiss-U.S. Data Privacy Frameworks (DPF) and the UK Extension to the EU-U.S. DPF as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from the EEA, Switzerland and the UK, respectively. Further details on the DPF can be found here; www.dataprivacyframework.gov
Our directors and other appointed individuals working for Inox may, in limited circumstances, access an individual’s contact information outside of the UK and European Union, e.g. if they are remote working, absent from the office and need to access critical business information or working abroad. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law, in line with the UK GDPR and the same legal protections that would apply to accessing personal data within the UK.
9. Data retention
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of a claim being made in respect to our relationship with you.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
10. What are your legal rights?
Under certain circumstances, you have rights under data protection laws in relation to your personal information. You have the right to:
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format.
Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us on the Contact Us page and filling out the webform.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.
We try to respond to all legitimate requests within one calendar month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. Children’s Privacy
For paying customers, Inox is a business to business website and thus is not structured to attract children. For non-paying customers Inox is intended to be used either in the context of a business to business website or by owners or occupiers of properties who are over 18 years of age. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18 years of age.
12. Commitment
We are committed to complying with the UK GDPR. Protecting your privacy online is an evolving area, and the Site is constantly evolving to meet these demands. If you have any comments or questions regarding our Privacy Notice, please contact us on the Contact Us page and filling out the webform. While we cannot guarantee privacy perfection, we will address any issue to the best of our abilities as soon as possible. This privacy notice was last updated on 29 October 2024.
You have the right to lodge a complaint with the Information Commissioner’s Office in the UK on the basis that this is where Inox is established.
Inox reserves the right to change this Privacy Notice at any time and in the event of change we intend to take every reasonable step to ensure that these changes are brought to your attention by confirming the date of the changes above. If in the event that we sell our business, customer information may be one of the transferred business assets. If this happens, your information will still be subject to this policy.
The information held and published on our website, associated websites is only to be used for the purposes for which it has been published. We do not consent to any organisation, or member of the public to take individuals’ (Data Subjects’) personal information from our website and use this for their own purposes.
13. Further Information
Questions regarding this Statement or the practices of this should be submitted on the “Contact Us” page webform. Details of the company’s registered office are available on the Site. Inox takes every effort to ensure that the information published on the Site is accurate. However, Inox cannot accept any liability for the accuracy or content. Visitors who rely on this information do so at their own risk. General information about data protection may be found at: Information Commissioner’s website; https://ico.org.uk/.
14. Third Party Recipients of Personal Information
We process some of your Personal Information using third party organisations. They are obligated to us to ensure that they process your data securely. We use the following organisations to process Personal Information for us:
Amazon Web Services (data storage, internal user management, database backups)
Google (email provider, video conferencing)
Slack Technologies (Communication platform)
