For the purpose of the Data Protection Act (“the Act”) and the General Data Protection Regulations (“GDPR”), that replace it from 25th May 2018, the data controller is Third Dimension Limited (“us”, “our” or “we”).
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
About Third Dimension Limited
Third Dimension is a limited company, registered in the United Kingdom and based at The Old Bank, High Street, Milborne Port, Sherborne, Dorset, DT9 5AQ, United Kingdom.
Third Dimension Limited owns the websites www.ipt.cc, www.igt.cc and www.icb.cc (IPT/ICB/IGT) which are B2B Trading Platforms specialising in helping brokers, traders, resellers and distributors in the open market.
The directors of Third Dimension Limited are committed to ensuring that the principles of GDPR are adhered to; that the rights of individuals under GDPR are appropriately protected; and that privacy by default and design is at the heart of our approach to data protection.
Information We May Collect From You
In our business as a provider of B2B trading Platforms, we may collect personal information from a range of subjects including, but not limited to:
- brokers, traders, resellers and distributors – prospective, current and past
- users of our professional services – potential, current and past
- people who we believe may be interested in our services, or who have expressed an interest in receiving our marketing material, or attending events organised by us
In respect of each subject class above, we may gather and hold the following personal information:
- personal identifiers such as name, address, phone, email, Skype, WhatsApp
- preferences with regards to areas of interest
- financial and other personal information required for the purposes of effecting a sale, purchase or completing a professional task such conducting mediation or issuing invoices
- some electronic data such as your IP address (your computer’s internet identity) and other details of visits to our websites. This data is not used by us, or any third party, to identify an individual.
We do not specifically process special category data such as nationality, sexuality, belief etc., nor do we collect personal data about children. Should we do so, we will ensure that extra safeguards are in place.
We may collect or hold data from the following sources:
- our Website, if you complete a form registering your interest in receiving further information
- registration of your interest in our services in person, in writing, by email, Skype, WhatsApp or on the phone
- gathered in the natural course of a transaction or ongoing professional service, where that data is relevant to performance of the contract, or legally required
- from our current databases of past and present clients, potential clients and applicants
How We May Use This Information – And The Legal Basis For Doing So
We may process this information for the following purposes:
- For the performance of a contract – including membership services – for the instigation and duration of that contract. We may hold all or part of that information for an indefinite period thereafter unless you ask us to desist.
- For the legitimate interests of ourselves and others in providing information to other members.
- For the fulfilment of a request by you, via our Website or other means, to provide details of forthcoming events; or other professional services. We will continue to supply you with such details until you ask us to desist. We have assessed that we have a legitimate interest in providing you with related information that we believe may be of interest or helpful to you in relation to your request. We will process your data until you ask us to desist.
- For the fulfilment of a legal or regulatory duty, for as long as that obligation persists.
- For the provision of marketing information about our services that we consider may be of interest to you, or that we believe may assist you in your move or professional requirements. We have assessed that this is a legitimate interest for the purposes of demonstrating the full breadth and quality of our services to our clients and potential clients. We do not believe that this offering is detrimental to the rights of those data subjects and, on balance, consider that it is less intrusive than obtaining specific consent to send marketing material. We will not supply this data to third parties, except solely to effect delivery of the material, and will unsubscribe subjects immediately on request.
- Other marketing information for which we may request your specific consent, having advised you of the purpose and relevant retention period.
We, or third-party processors, may use limited automated decision-making for the following purposes: referencing or money-laundering checks, which are necessary for legal or contractual purposes. We ensure that there is human intervention to refine the automated results where necessary, and allow you to challenge the results or the data input to reach the decision.
Sharing Your Personal Data
We may share your data with third parties, either directly or in passing, for the following purposes:
- To help us in the fulfilment of a contract or service to you, including our current providers of the following services:
- Credit Checking
- Money-laundering checking
- To assist us in the running of our own business, including our current providers of the following services:
- Accounts and payment processing software
- Website and IT services
- As required to authorities or regulators, including:
- HMRC and FCA
- Enforcement agencies
- For the delivery of our own marketing material via printing or delivery businesses
- After assessment, to meet the legitimate interests of others in referencing, debt-collection, managing insurance claims and the like.
We do not sell data to third parties.
Security of Your Data
We are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage to personal data.
This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies to all UK national laws and requirements for user privacy.
Cookies are small files saved to the user's computer hard drive that track, save and store information about the user's interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.
Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.
Other cookies may be stored to your computer hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
Contact & Communication
Users contacting this website and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed in the Data Protection Act 1998. Every effort has been made to ensure a safe and secure form to email submission process, but advise users using such a form to email processes that they do so at their own risk.
This website and its owners use any information submitted to provide you with further information about the products / services they offer or to assist you in answering any questions or queries you may have submitted. This includes using your details to subscribe you to any email newsletter program the website operates, but only if this was made clear to you and your express permission was granted when submitting any form to email process. Or whereby you the consumer have previously purchased from or enquired about purchasing from the company a product or service that the email newsletter relates to. This is by no means an entire list of your user rights in regard to receiving email marketing material. Your details are not passed on to any third parties.
We inform our subscribers about products and services supplied by this website. Users can subscribe through an online automated process should they wish to do so, but do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user (this can by letter, WhatsApp, email or Skype).
Subscriptions are taken in compliance with UK Spam Laws detailed in the Privacy and Electronic Communications Regulations 2003. All personal details relating to subscriptions are held securely and in accordance with the Data Protection Act 1998. No personal details are passed on to third parties nor shared with companies / people outside of the company that operates this website. Under the Data Protection Act 1998 you may request a copy of personal information held about you by this website's email newsletter program. A small fee will be payable. If you would like a copy of the information held on you please write to the business address at the bottom of this policy.
Email marketing campaigns published by this website or its owners may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity [this is by no far a comprehensive list]. This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.
In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003 subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will by detailed instead.
Our email communications is currently run through MailChimp.
Although this website only looks to include quality, safe and relevant external links, users are advised adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text / banner / image links to other websites).
The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Adverts and Sponsored Links
This website may contain sponsored links and adverts. These will typically be served through our advertising partners, to whom may have detailed privacy policies relating directly to the adverts they serve.
Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
Shortened Links in Social Media
This website and its owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy urls [web addresses].
Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
Your Rights in Respect of Your Data
GDPR clarifies a number of rights for data subjects, which are summarised below:
- Right to be informed – we should tell you what data we hold and what we do with it
- Right of access to your data – to know what data we hold on you
- Right to rectification and erasure – if you would like us to correct an inaccuracy or, where legally possible, to delete or anonymise your data
- Right to restrict processing or object to our processing data
- Right to portability of data – so that you can see and use the data for your own purposes
If you wish to exercise any of these rights, you should contact us as set out below.
Updates to Our Privacy Policies
We may update our policies from time to time if operational needs or legislation requires amendment. New versions of the policies will be published on our website or available on request, but will not otherwise be notified.
It is our intention that we should adopt best practice to comply with the complicated and developing requirements of GDPR. However it may be that we have not interpreted the guidelines, or effected them in practice, as we should. If that is the case, we would prefer that you address any concerns in the first instance to us and we will do our absolute best to deal with the issue to your satisfaction in the appropriate timeframe.
Should you have any queries about our policies, or wish to exercise any rights conferred under GDPR, please email firstname.lastname@example.org or write to The Data Controller, Third Dimension Limited, The Old Bank, High Street, Milborne Port, Sherborne, Dorset, DT9 5AQ United Kingdom. If you are exercising any rights, we will ask you to verify your identity and detail your request in writing.
There is additionally much relevant information on the website of the Information Commissioner’s Office at www.ico.org.uk, including the ability to report a concern directly to them, should you wish to do so.
v.1.2 June 2018
Edited & customised by: Third Dimension Limited, The Old Bank, High Street, Milborne Port, Sherborne, Dorset, DT9 5AQ United Kingdom