Privacy policy and cookies policy

 

1.    PRIVACY POLICY 

Inkpath Limited (company number 10530056) ("Inkpath" / "we" / "our" / "us") takes your privacy very seriously and is committed to protecting and respecting your privacy.

This privacy policy (together with the Inkpath Platform terms of use, which you can find here, and the Website terms of use, which you can find here) sets out the basis on which any personal data we collect from you, or that you provide through your use of the Inkpath website (www.inkpath.co.uk) (the “Website”) or the Inkpath Platform, will be processed by us.  The Inkpath mobile application (the “Inkpath App”), certain parts of the Website, which you can only access if you have an account with us, and any updates or supplements to them are collectively referred in this policy as the “Inkpath Platform”. 

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. 

Inkpath is the data controller.  Our registered office is 30 Upper High St, Thame OX9 3EZ. 

This privacy policy applies to:

  • Visitors of the Website, i.e. someone who is only visiting the Website, but is not accessing the Inkpath Platform; 
  • Users of the Inkpath Platform, i.e. someone who uses the Inkpath Platform to plan and track their career development; and / or  
  • Organisation Staff Members, i.e. someone who has been administrative access rights to the Inkpath Platform and is using the Inkpath Platform to administer their Organisation’s activities, courses, lectures or tutorials, set tasks for Users, review feedback given by Users (etc) and carry out supervisory tasks.  You will have been given access to the Inkpath Platform pursuant to the Customer Agreement entered into between us and the Organisation as explained in more detail below.

CUSTOMER AGREEMENT 

Unless you are a Visitor or User, Inkpath will have entered into an agreement with the organisation that you represent (the “Organisation”) for the use of the Inkpath Platform (the “Customer Agreement”).  Please note that the information the Organisation or you provide to us (whether it is personal or non-personal information) will also be governed by the Customer Agreement. 

WHICH PROVISIONS OF THIS PRIVACY POLICY APPLY TO YOU?

Provisions of this privacy policy, which do not state who they apply to, apply to all Visitors, Users and Organisation Staff Members.  Please note that you may be a Visitor, User and/or Organisation Staff Member depending on your interaction with us.

DATA WE COLLECT FROM YOU 

We will collect the following data about you: 

Data you give us.  You may give us data about you: 

  • when you download or register to use the Inkpath App; 
  • when you register to use the Inkpath Platform on the Website; 
  • when you report a problem with the Website, Inkpath Platform or Inkpath App; 
  • if you complete a survey or provide feedback, for example, about an activity, course or lecture you have attended at the Organisation, the Inkpath Platform, Inkpath App or the Website; and
  • if you contact or correspond with us (for example, by phone, e-mail or otherwise) for any other reason. 

The data you give us may include your name, address and your Organisation e-mail address. 

If you are a User, you:

  • must provide us with information about yourself, such as your name and age; 
  • must tell us what Organisation you are part of, for example, if you are a student you will be asked to let us know what University and College (if applicable) you attend; 
  • must provide us with your personal email address so we can contact you and you can access your account once you have left the Organisation;
  • must also tell us your start date at the Organisation; 
  • may provide us with your education and employment history (including job titles), and any other institutional affiliations; and
  • may provide us with information about what programmes you wish to undertake, your goals, activities you wish to join and skills you wish to develop. 

If you are an Organisation Staff Member, you:

  • must provide us with information about yourself, such as your name; 
  • must tell us what Organisation and department or team you belong to; and
  • may provide us with information about what programmes or activities you wish Users to undertake or join, skills they may wish to develop or goals they may wish to set themselves.  

When you sign up to the Inkpath Platform, the sign up form will clearly set out which details you must provide us with in order to successfully sign up and use the Inkpath Platform. If you do not provide us with this information, you will not be able to use the Inkpath Platform.

Data we collect about you.  

  • When you use the Inkpath Platform, details of your usage (including the data, time, location or duration of the usage). 
  • If you visit the Website or use the Inkpath Platform, we will automatically collect certain technical information, for example, the type of device (and its unique device identifier) you use to access the Website or the Inkpath Platform, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform. 
  • We will automatically collect information about your visit to the Website including the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. 

Data provided by the Organisation.  

  • If you are a User or an Organisation Staff Member, we will be provided with or obtain information about you from the Organisation, for example, to verify your eligibility to register and use the Inkpath Platform.  

USES MADE OF THE DATA 

Please note that we may use and share non-personal data we receive or collect from you in connection with the Inkpath Platform. 
We will use the above personal data held about you:

  • to enable you to use the Inkpath Platform; 
  • to carry out our obligations arising from the Customer Agreements;
  • if you are a User, to carry out our obligations arising from our relationship with you and to provide you with information and services that you request from us; 
  • if you are a User or Organisation Staff Member, to help us identify you and any accounts you hold with us; 
  • if you are a User or Organisation Staff Member, to verify your eligibility to access and use the Inkpath Platform; 
  • to carry out surveys and market research; 
  • to conduct research, statistical analysis and behavioural analysis;
  • to deal with any enquiries, correspondence, concerns or complaints you have raised; 
  • for our internal operations, including data analysis, testing, research, statistical purposes and troubleshooting; 
  • to ensure that content on the Website and Inkpath Platform is presented in the most effective manner for you and for your device;
  • as part of our efforts to keep the Inkpath Platform secure; 
  • to notify you about changes to any element of the Inkpath Platform or the Website;   
  • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about. We will only contact you by e-mail with such information if you have consented to this. More information about this is set out below under the heading “legal basis for processing”;
  • to measure and understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, for example, newsletters; and
  • to make suggestions and recommendations to you about our other apps, upgrades, products or services that may interest you.

We may also use your personal data when carrying out automated decision-making and profiling, which is intended to evaluate certain personal aspects. For example, we may analyse your course choice, employment or education history to propose job opportunities to you and put you in touch with prospective employers. We will ask you to consent to this type of processing, and this is explained in more detail below. 

MARKETING

As mentioned above, we would like to send you information by email or direct app-based notifications about products, services and opportunities which may be of interest to you.

We will not provide your personal data to other businesses so they can use your personal data for marketing purposes.  

We will only ask whether you would like us to send you marketing messages when you tick the relevant boxes when you sign up to the Inkpath Platform for the first time. You will have the opportunity to clearly set out what messages you wish to receive by ticking these boxes, for example, you may be interested to hear about job opportunities generally or you may only be interested to hear about job opportunities directly relevant to your field.  

You can also manage your preferences by updating / changing your privacy settings of your account. 

DISCLOSURE OF YOUR PERSONAL DATA 

If you are a User then we will share some of your personal data with the Organisation and certain Organisation Staff Members so you can make the most of using the Inkpath Platform and your career development. For example, your tutor, mentor or supervisor will be able to see some of your personal data, for example, your name, position within the Organisation (that is, your department or team), and list of activities completed to date at the Organisation. The information we share with the Organisation is further intended to enable it to be used for analytical purposes and programme and product development purposes and to administer and facilitate the Organisation’s or the Organisation Staff Members’ use of the Inkpath Platform.   

You will be able to mark personal data or other information you add to the Inkpath Platform as “private”, which means the Organisation or Organisation Staff Members will not have access to it, for example, activities which are deemed sensitive by the Organisation or Organisation Staff Members and you therefore do not wish to share it, or if you attend a seminar or activity outside the Organisation and you then upload this to the Inkpath Platform.  You may also mark information as “private” if you would like to retain it for your use only and not share it with the Organisation. You can find further information about this here

If you are an Organisation Staff Member then your personal data will be shared with the Organisation and other Organisation Staff Members (for example, your supervisor or head of department) will have access to your personal data to enable the Organisation to administer and facilitate its and your use of the Inkpath Platform.  Please remember that Users will also have access to or see certain information. For example, when signing up to activities or courses, or when agreeing goals and tasks with you. 

You agree that we may share your personal data with the following categories of selected third parties in accordance with this policy: 

  • service providers (for example, IT services), business partners, suppliers and sub-contractors for the performance of any contract we enter into with you or the Organisation (such as the Customer Agreement), but also when sending out newsletters; 
  • analytics and search engine providers that assist us in the improvement and optimisation of the Website, the Inkpath Platform and the Inkpath App; 
  • in the event that we sell any business or assets or receive investment into our business, in which case we may disclose your personal data to the prospective buyer or investor;
  • if Inkpath or substantially all of its assets are acquired by a third party, in which case personal data held by us, including your personal data, will be one of the transferred assets; and
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the Inkpath Platform terms of use or the Website terms of use or any other contract between you and us or between the Organisation or us; or to protect the rights, property or safety of Inkpath, our users, and others. 

You also agree that we may share your personal data in a pseudonymised form with the Organisation for the purposes of improving their educational provision, producing bids for funding, and reporting for external funding organisations such as the UK Research Councils.  “Pseudonymised” personal data means data that cannot be connected to an individual without the use of additional information, which is kept separately to ensure confidentiality.  We would achieve this by deleting names, email addresses and other identifying information, and instead attaching a code to each data set.

LEGAL BASIS FOR PROCESSING 

For some of the uses of your personal data (as described above) there is a legal basis under applicable data protection laws for us to use such personal data without your consent.  This includes, for example, where it is necessary for us to use the information in order to provide the Inkpath Platform to you or where we have a legitimate interest to use it (a) to ensure that we understand who and how the Inkpath Platform is used; and (b) to improve the Inkpath Platform and ensure it is secure; (for example, for statistical, testing and analytical purposes, troubleshooting or to carry out surveys and market research). Where this is the case, this privacy policy fulfils our duty to process personal data fairly and lawfully and in a manner that you would expect given the nature of our relationship with you or the Organisation, by giving you appropriate notice and explanation of the way in which your personal data will be used.  

Where consent is required for our use of your personal data, by ticking the appropriate consent box  or otherwise communicating your consent (for example, by email or by providing us with non mandatory information), you consent to our use of that personal data as set out in this policy. For example, we will only process your personal data for marketing purposes or automated decision making or profiling if we have your consent to do so. 

You can always change your mind about our processing of your personal data. If you change your mind you can update your account settings within the Inkpath Platform, or contact us by email at admin@inkpath.co.uk, or in respect of marketing messages you can unsubscribe by using the unsubscribe link at the bottom of our marketing messages. 

WHERE WE STORE YOUR PERSONAL DATA

The personal data that we hold about you will only be processed and stored within the United Kingdom.

SECURITY 

All information you provide to us is stored on secure severs. We will use technical and organisational measures to safeguard your personal data. 
Where we have given you (or where you have chosen) a password which enables you to access the Inkpath Platform (via the Inkpath App or web browser), you are responsible for keeping this password confidential.  We ask you not to share your password with anyone.  

Unfortunately the transmission of information via the Internet is not completely secure.  Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the Inkpath Platform; any transmission is at your own risk.  Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access. 

RETAINING PERSONAL DATA 

We will retain the personal data we receive or collect about you for the period reasonably required for us to use it in accordance with this privacy policy or in accordance with our legal rights and obligations. 

The Inkpath Platform is a tool for life.  Unless we inform you otherwise (or you request that we erase your personal data), we will retain your personal data on record for as long as you continue to use the Inkpath Platform.  However, if you do not use the Inkpath Platform for 6 months then we will contact you to inform you that your data / account will be deleted within 6 months unless you access your account to stop this process. 

In any case we may retain some of your personal data for 6 years after you stop using the Inkpath Platform, for legal reasons. 

YOUR RIGHTS 

You have the following rights with regard to your personal data: 

  • Access.  You have the right to access data we hold about you.  We will need you to prove your identity before we release any personal data to you.  
  • Rectification or erasure. You have the right to request that we rectify or delete any personal data that we hold about you (unless we have the legal right to retain it). 
  • Restriction.  You also have the right to restrict us from processing your personal data if the data is inaccurate, the processing is unlawful or we no longer need to your personal information for the purposes of the processing. 
  • Change of preferences. You can change your data processing preferences at any time. For example, if you have given your consent to direct marketing, but have changed your mind, you can opt out of receiving marketing communications by contacting us using the details provided below or clicking the relevant link in any communication you receive.
  • Complaints. If for any reason you are not happy with the way that we have handled your personal data, please contact us.  If you are still not happy, you have the right to make a complaint to the Information Commissioner’s Office. 
  • Data portability. You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller if the legal basis for processing such personal data is consent.  
  • Automated decision making.  If you have any questions in respect of our automated decision-making processes or the accuracy of them, please let us know.  

Please note that if you ask us to stop processing your personal data in a certain way or erase your personal data, and this type of processing or data is needed to facilitate your use of Inkpath Platform you may not be able to use the Inkpath Platform as you did before.  This does not include your right to object to direct marketing, which can be exercised at any time without restriction.  Please allow at least 3 working days for your request to be actioned.
 
Please note that the rights mentioned above do not extend to non-personal data.  Please also note that it is likely to be necessary to retain your personal data for the purposes of assessing and verifying data that is submitted and/or held on the Inkpath Platform and to manage the Inkpath Platform, so therefore your rights under applicable law to request erasure may be limited accordingly. 

If you would like to exercise any of the rights mentioned above, please contact us by emailing us at admin@inkpath.co.uk.
 
2.    COOKIE POLICY 

We use cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your computer or mobile device if you agree. Cookies contain information that is transferred to your computer's or mobile device’s hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of the Website and the Inkpath Platform. They include, for example, cookies that enable you to log into the Inkpath Platform either via the Inkpath App or via the Website. 
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. They also enable us to see how users use the Inkpath Platform and the Inkpath App.  This helps us to improve the way the Website, the Inkpath Platform and the Inkpath App work. 
  • Functionality cookies. These are used to recognise you when you return to the Inkpath Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to the Website or the Inkpath Platform, the pages you have visited and the links you have followed. We will use this information to make the website and the advertising displayed on it more relevant to your interests. 

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Purpose
_ga This cookie is essential for Google Analytics service used by the Website to distinguish users.
_gid This cookie is essential for the Google Analytics service used by the Website to distinguish users.
_gat This cookie is essential for the Google Analytics service used by the Website to throttle the request rate.
XSRF-TOKEN This cookie is essential for the Inkpath Platform to prevent cross-site request forgery which is a type of malicious exploit of a website where unauthorised commands are transmitted from a user that the web application trusts.
laravel_session This cookie is essential for the Inkpath Platform to ensure that user is recognised when moving from page to page within the web site.
Local storage This cookie is essential for the Inkpath Platform to act as data cache and avoid service interruption when the network connection is poor or not available.


By clicking “agree” on the cookie consent box when you first access the Website or the Inkpath App and by continuing to access and use Website and the Inkpath App (as applicable) you accept our use of the cookies. 

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website or the Inkpath App. 

For more detailed information about cookies and how they can be managed and deleted, please visit www.allaboutcookies.org

3.    CHANGES TO THE PRIVACY POLICY AND COOKIE POLICY 

Any changes we make to our privacy and cookie policies in the future will be hosted on www.app.inkpath.co.uk and, where appropriate, notified to you by e-mail or pop-up in the Inkpath Platform when you first access the Inkpath Platform after a change has been made.  Please check back frequently to see any updates or changes to our privacy and cookies policies.  Continued use of the Website or Inkpath Platform (as appropriate) will signify that you agree to such changes. 

4.    CONTACT

Questions, comments and requests regarding the privacy policy and the cookie policy are welcomed and should be addressed to Inkpath Limited at 30 Upper High St, Thame OX9 3EZ or admin@inkpath.co.uk.   

Please also contact us if you would like to know more about our data processing activities, to update or amend any of your personal data which you have provided to us or if you believe our records relating to your personal data are incorrect. 

These policies were last updated on 2 October 2017.