Privacy Notice

Version: 1

March 15th 2024

LAST UPDATED: March 15th 2024

1. Introduction

1.1 Scope

2. Personal Data we collect and the sources

2.1 What we mean by 'Personal Data'

2.2 Who we collect data about

2.3 Types of Personal Data we collect

3. How we use the Personal Data we collect

3.1 Consent

3.2 Contract

3.3 Legitimate interests

3.4 Legal Obligation

4. How we share or disclose Personal Data

4.1 Information you share

4.2 Information we share

5. How long we keep your personal data

6. Personalised marketing and cookies

7. Our safety to minors

8. Data Transfers

9. Who is my Data Controller?

10. Your rights

10.1 Knowing your rights

10.2 Exercising Your Rights

11  Contact Us

12. Changes to our Privacy Notice

1. Introduction

1.1 Scope                

Company Number 14672340, 128 City Road, London, EC1V 2NX, United Kingdom        

Welcome to Ideaonomy Ltd’s Privacy and Data Protection Policy (“Privacy Notice”).

This Privacy Notice applies to all the products, services, websites, and applications offered by Ideaonomy Ltd., including those that are currently in development and those that have been launched and are available to users. Throughout this notice, we collectively refer to these products, services, websites, and applications as our "services."

Unless otherwise specified in your contract with us, Ideaonomy Ltd. is the provider of these services within the United Kingdom and all other regions where we operate. This means that Ideaonomy Ltd. is the data controller responsible for the processing of your personal data in connection with our services, as outlined in this Privacy Notice.

We are committed to protecting your privacy and ensuring that your personal data is processed in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR) for individuals within the European Economic Area (EEA) and the United Kingdom.

This Privacy Notice applies to personal information we collect from our employees or job applicants in their capacity as employees or candidates.

Data We May Collect in the Future

Ideaonomy is constantly evolving, and will introduce new features in the future that require the collection of additional data. When this happens, we will update this privacy notice to reflect the new data practices and obtain your consent if necessary.

2. Personal Data we collect and the sources

2.1 What we mean by 'Personal Data'

Personal data is defined as per the UK GDPR, which is as follows as:

“‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

2.2 Who we collect data about

We collect data about various types of individuals who interact with our services. These individuals may be consumers or businesses, and their level of engagement with our services varies depending on their specific role and interaction with our platforms:

  • Host: the business or consumer that holds an account within an Ideaonomy service. For Hosts, we may collect account registration information, billing details, and data related to their use of our services.
  • Respondent: Individuals who participate in interactive elements powered by Ideaonomy. For Respondents, we may collect information provided through their participation, such as survey responses or leaderboard submissions.
  • Visitor: People who visit our website for various reasons, like browsing out of curiosity, being invited to review a leaderboard, or learning about us through marketing channels.

2.3 Types of Personal Data we collect

  1. Contact information.

When you interact with our services, website, sales, or customer support team you may provide us with your contact information, such as name or email address

  1. Diversity and inclusion.

In our efforts to promote diversity and inclusivity within our services, we may collect certain personal data related to diversity, such as age, gender, race, ethnicity, sexual orientation, disability status, or other relevant demographic information. This data is collected on a strictly voluntary basis, and users can choose not to provide this information if they prefer.

We collect this data to better understand the diversity of our user base, identify potential areas for improvement, and make informed decisions to ensure our services are inclusive and accessible to all. This data is treated with the utmost confidentiality and is used solely for the purpose of promoting diversity and inclusion within our services. You have the right to request the deletion of their diversity and inclusion data at any time, and we will promptly comply with such requests.

(c) Cookie and tracking technologies.

We use cookies and tracking tools to collect data about website usage and user statistics. Emails sent by Ideaonomy or users may also contain tracking technology.

(d) Customer support information.

We collect information submitted through our website for customer support, such as name, email, and message text.

(e) Usage information.

We collect usage information about you whenever you interact with our websites and services. This includes webpages visited, clicks, language preferences, and purchases

(f) Device and browser data.

We collect information from the device and application you use to access our services, including IP address, operating system version, device type, device ID/MAC address, system and performance information, browser type, and geographic location inferred from your IP address. This data is processed based on our legitimate interest in providing and improving our services and ensuring their security.

(g) Event data.

Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps.

(h) Referral information.

If you arrive at an Ideaonomy website from an external source (e.g., a link on another website or in an email) or have been invited to review a leaderboard, we record information about the source that referred you to us.

(i) Integration data.

We collect information from third parties with whom Ideaonomy enables integrations in order to allow you to use both services.

(j) Account information.

  • Registration information.
    • When you create an Ideaonomy account to use our services, we collect personal data that you provide during the registration process. This may include, but is not limited to, your name, email address, username, password, and other relevant information necessary for account creation and management.
  • Billing information.
    • When you make a payment to Ideaonomy for our services, we collect the necessary billing information to process your payment and comply with our legal obligations. This may include your name, billing address, email address, and financial information specific to your chosen payment method, such as credit card details or bank account information. We process this data to fulfil our contractual obligations to you and to comply with applicable tax and accounting requirements.
    • Your billing address may be used to determine the appropriate Ideaonomy entity with which you have a contract and to calculate any applicable sales tax. We will retain your billing information for as long as required by law for tax and accounting purposes.
  • Account settings.
    • You will be able to set various preferences and personal details relating to your account. These may include, your default language, time zone and communication preferences such as opting in or out of receiving marketing communications from Ideaonomy.

(k) Contact information for invitations

Ideaonomy may provide you with the option to import email addresses and other contact information from your address book or contacts to make it easier for you to invite others to participate in Ideaonomy. If you choose to use this feature, please note that you are responsible for ensuring that you have the necessary consent or legal basis to share these contact details with Ideaonomy. Ideaonomy will not use this data for our own purposes or to contact anyone, except at your direction.

(l) Leaderboard/form/application data.

We store your leaderboard/form/application data (e.g., problems and responses) for you and provide analysis tools for you to use with respect to this data.

(m) Profile information.

When you sign up for our services you are asked to provide us with information about yourself and to give us more detailed insights into who you are. If you are in an Ideaonomy Enterprise account this may include providing your photo so your administrator(s) and colleagues can identify you.

We may combine information about you from third party sources (such as LinkedIn, ZoomInfo, and other data brokers) with information we hold about you to create a user profile.

3. How we use the Personal Data we collect

We process Personal Data about you based on your consent, to fulfil our contractual responsibilities, for our legitimate interests, and to comply with legal obligations. The specific ways we use your data may vary depending on your role as a Host, Respondent, or Visitor.

3.1 Consent

We rely on your consent to process the following data elements:

(a) Cookies and similar technology: We or a third-party and advertising platforms may collect data from cookies, page tags, mobile identifiers, and IP addresses to infer users' identities across different services and devices. This data is used to tailor ads, personalise marketing, determine the success of advertising campaigns, and improve upon them. You can withdraw your consent at any time.

(b) Contact information: We use contact information to respond to inquiries, send service-related information, and marketing materials (where opt-in has been given).

3.2 Contract

We collect and use the following data elements to fulfil our contractual responsibilities:

(a) Account information: To manage your account, provide services, bill you, provide customer support, and contact you about your service or account.

(b) Customer support information: To provide customer support through our portal.

(c) Usage information: To ensure we meet our service-level agreements (SLAs) or other contractual obligations, and to provide services to Hosts, such as preventing duplicate submissions.

(d) Device and browser data: To troubleshoot problems, make improvements, facilitate account verification and sign-in, enforce security policies, and provide services to Hosts.

(e) Integration data: To enable sign-up and use of our service with third-party integrations.

(f) Leaderboard interactions and response data: We employ AI techniques, including machine learning, on aggregated and anonymised/pseudonymised leaderboard data to provide valuable insights to Hosts or third parties. You can choose whether to use these AI-driven features.

(g) Comments/content: Any comments or content linked to you based on collaborating on content on Ideaonomy’s services.

3.3 Legitimate interests

We process the following data categories for legitimate interests:

(a) Customer support information, such as to train AI algorithms for better prediction and answering of customer support questions, generating insights, and improving customer support using de-identified data.

(b) Usage information, such as to improve our services, make recommendations, optimise user experience based on your usage patterns and account behaviour, and understand trends in service adoption.

(c) Event data, such as to create new services, features, content, make recommendations, understand trends, fix bugs, troubleshoot, investigate security issues, monitor abuse, and track preferences.

(d) First-party and third-party information, such as to provide a personalised experience, offer relevant marketing information, make product, feature, and service recommendations, and create user profiles for more relevant sales and marketing efforts and improved service experience, where permitted by law.

(e) Referral information, such as to track the success of integrations and referral processes, such as advertising campaigns.

(f) End page data, such as to include surveys and polling learnings, which are optional for respondents.

(g) Anonymised data, we process aggregated or anonymised data such as, device data, leaderboard data, and response data, to extract usage patterns, improve our services, and develop new features and functionalities. This data is processed in a manner that ensures individuals cannot be re-identified, in compliance with the GDPR's requirements for anonymisation. The anonymisation process irreversibly alters the personal data so that it can no longer be attributed to a specific individual, even when combined with other data sources.

3.4 Legal Obligation

(a) To respond to legal requests, such as subpoenas, we may need to use and disclose information we hold about you.

(b) We may also use usage data, event data, and aggregated or anonymised data to enforce agreements, investigate security issues, prevent unlawful activities, and screen for undesirable or abusive activity.

4. How we share or disclose Personal Data

4.1 Information you share

Many of our services let you share information with others. Remember that when you share information publicly, it can be indexable by search engines. Our services will provide you with different options on sharing and deleting your content but we cannot delete content from search engines so you need to be careful about information you make public.

4.2 Information we share

We do not share your information or data with third parties outside Ideaonomy except in the following limited circumstances:

(a) Ideaonomy Enterprise plan: If you are a Host or part of an Ideaonomy Enterprise plan, your account information, leaderboard data, and other relevant data may be shared with or visible to the primary administrator(s) and other team members, as necessary. Your administrator(s) may have control over your account settings and data. Please refer to your organisation's internal policies for more information.

(b) Migration to Ideaonomy Enterprise account: If your organisation purchases an Ideaonomy Enterprise account and you are using an email address owned by your employer or organisation, you may be asked to migrate to the Enterprise account. After migration, your email address, name, and account data will be visible to the primary administrator(s). You will receive advance notification and have the opportunity to change your email address if you are not using the account for business purposes.

(c) We partner with trusted third-party service providers to help us deliver various functionalities for our services. These partnerships ensure we can offer a comprehensive and secure experience.

The data shared is limited to what's necessary for the specific service, here are some examples of how we work with these partners,

  • Facilitating Service Delivery: We partner with providers to enable features like sending leaderboards to Respondents (sharing relevant contact information) or processing payments for Hosts.
  • Enhancing Features: to identify or further develop certain features, such as "Create a leaderboard using AI," which may involve sharing anonymised data with our AI vendor to generate insights.
  • Security and Maintenance: We collaborate with partners to detect fraudulent activity (e.g., verifying IP addresses) and maintain a secure platform.
  • Marketing and Analytics: We may partner with providers to deliver targeted marketing content and track website conversion metrics.
  • Customer Support: To offer efficient sales and customer support, we may collaborate with partners who manage these interactions.

If you agree to these terms and conditions, Ideaonomy can share your data with our partner companies so that they may offer you their products and services. For specific collaboration projects, we might explore data partnerships with clear contractual agreements outlining data usage limitations and user consent (if applicable).

Such as, data generated at the Innovation Zero event 2024 hosted by Clean Tech Events Ltd will be shared with Clean Tech Events Ltd in order to facilitate post matching of users of the same problem statements and domains to build networks and solutions to solving those given problems.

Such as, Investor partnerships in order to determine trends and matches to funding opportunities to assist in delivery of a given solution to a problem.

(d) We enter into confidentiality and data processing agreements with our partners to ensure they adhere to high standards of confidentiality, privacy, and security. We regularly review these standards and practices to ensure compliance with GDPR requirements.

(e) On your instructions, we share your information or data if you choose to use an integration in conjunction with Ideaonomy services, to the extent necessary to facilitate that use.

(f) We also may be required to share information or data for the following purposes:

  • To meet any applicable law, regulation, legal process or enforceable governmental request;
  • To enforce applicable policies, including investigation of potential violations;
  • To detect, prevent, or otherwise address fraud, security or technical issues;
  • To protect against harm to the rights, property or safety of our users, the public or to Ideaonomy and/or as required or permitted by law; and
  • To facilitate a sale, merger or change in control of all or any part of our company or business or in preparation for any of these events.

5. How long we keep your personal data

We only retain your information for as long as is necessary for us to use your information as described above, where it is in our legitimate interest, or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance, if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.

When determining the relevant retention periods, we will take into account factors including:

  • Our contractual obligations and rights in relation to the information involved;
  • Legal obligation(s) under applicable law to retain data for a certain period of time;
  • Our legitimate interest where we have carried out a balancing test;
  • Statute of limitations under applicable law(s);
  • (potential) disputes;
  • If you have made a request to have your information deleted; and
  • Guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information once this is no longer needed.

If you are a Host, we generally do not delete the data in your account as long as your account is active – you are responsible for and control the time periods for which you retain this data. Here are some exceptions: 

  • If you are an Ideaonomy Basic (free) user on our platforms and you have not engaged with the service actively for some time, we reserve the right to delete your account and data in accordance with our data retention policy. 
  • If you have exceeded your response limit as an Ideaonomy Basic (free) account holder, we will delete the overages if you do not upgrade within a fixed timeframe. 

We also encourage Hosts to actively review their data retention practices in their account and take care to retain data only as long as is strictly necessary.  

6. Personalised marketing and cookies

We and our partners use cookies and similar technologies. If you are a customer of Ideaonomy and separately use cookies or similar technologies in conjunction with any of our products and services, then you yourself will be responsible for complying with any laws related to the use of those technologies and this Privacy Notice is not applicable to that use by you.

You will be able to also choose to remove or disable cookies via your browser settings  and, depending on your geographic location you will be able to withdraw consent to non-essential cookies using the in-product cookie preferences tool.

By default users are opted out of marketing materials. A user who has opted in will be able to opt-out from direct marketing in your account and we provide opt-out options in all direct marketing emails. Finally, if you do not wish to see personalised marketing content on the web related to our service you will be able to clear the cookies in your browser settings.

7. Our safety to minors

Our services (including creating and responding to leaderboards) are not intended for and may not be used by minors. “Minors” are individuals under the age of 16 (or under a higher age as provided in certain countries or territories). Ideaonomy does not knowingly collect Personal Data from Minors. Upon full user registration feature Ideaonomy will ask ‘are you above the legal age consent?’. If it comes to our attention that we have collected Personal Data from a Minor, we may delete this information without notice. If you have reason to believe that this has occurred, please contact us.

8. Data Transfers

Your information and data may be processed in and transferred or disclosed in the United Kingdom or United States and countries in which our affiliates are located and in which our service providers are located or have servers. We ensure that the recipient of your Personal Data offers an adequate level of protection, for instance by entering into the appropriate back-to-back agreements with standard contractual clauses or other transfer mechanisms as approved by the European Commission or relevant data protection authority.

9. Who is my Data Controller?

When Ideaonomy processes personal data on behalf of companies that own their Ideaonomys, Ideaonomy is acting as a data processor. The companies (Hosts) are the data controllers in this case. However, Ideaonomy may agree with a given company to also use the data for its own purposes, such as product improvement, Ideaonomy may be considered a joint controller for those specific processing activities. This only applies if we are using data that could still identify individuals (even indirectly) for product improvement.

Example, if you have provided leaderboard responses, filled out a form, submitted an application, or provided website feedback to a Host using Ideaonomy services, that Host is the controller of your data, and Ideaonomy is the processor of that data. 

When Ideaonomy collects personal data through its own website or through a public Ideaonomy hosted by Ideaonomy, Ideaonomy is acting as the data controller.

Ideaonomy will be considered a Data Processor whereby it uses anonymised data from companies' Ideonomy for product improvement.  Anonymised data is not considered personal data under GDPR.

We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to impact@ideaonomy.ai or by post to 128 City Road, London, EC1V 2NX, United Kingdom.

10. Your rights

10.1 Knowing your rights

Ideaonomy is committed to upholding your rights under the General Data Protection Regulation (GDPR). As a data subject, you have the following key rights

  • Right to Access: You have the right to request a copy of your personal data that we hold, free of charge and in a commonly used electronic format.
  • Right to Rectification: If your personal data is inaccurate or incomplete, you can request its correction or completion.
  • Right to Erasure (Right to be Forgotten): In certain circumstances, you can request the deletion of your personal data, subject to legal requirements.
  • Right to Restriction of Processing: You can request that we restrict the processing of your personal data, meaning we can store it but not use it further.
  • Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request its transfer to another controller, if technically feasible.
  • Right to Object: You can object to the processing of your personal data for marketing purposes or where the processing is based on legitimate interests.
  • Right to Withdraw Consent: If you have consented to the processing of your personal data, you can withdraw your consent at any time.

Further information and advice about your rights can be obtained from the data protection regulator in your country.

If you do not provide the personal information necessary or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide services to you, we will not be able to provide these services to you.

10.2 Exercising Your Rights

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section. We will respond to your request within 30 days of receipt.

If you are an Ideaonomy user, please see information on how to exercise your rights here.

If you have visited our website and wish to exercise your rights, please contact our support team. To exercise your right to be forgotten in relation to our use of cookies, you can clear the cookies in your browser settings.                                

If you have provided personal data to a Host using Ideaonomy services, please contact the Host directly to exercise your rights, as they are the data controller. If you have difficulty locating the Host or have any other questions, please contact our support team for assistance.

If you are an authorised agent acting on behalf of a data subject to exercise their rights, please follow the process outlined in this Privacy Notice. We will verify the data subject's identity directly through their registered email address.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

11  Contact Us

Ideaonomy Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to impact@ideaonomy.ai or by post to:

128 City Road,

London,

EC1V 2NX,

United Kingdom.

12. Changes to our Privacy Notice

We can make changes to this Privacy Notice from time to time. In circumstances where a change will materially change the way in which we collect or use your personal information or data, we will send a notice of this change to all of our account holders. 

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