Privacy Policy
ICS is committed to protecting the privacy of your personal data. This policy describes what kind of personal data we collect, how we use it and who we share it with. Furthermore, the policy describes the security measures set out to protect the personal data and your rights in relation to the data.
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In this policy, ICS means Investment Control Solutions Pty Ltd. and any of its affiliates.
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1. What personal data does ICS collect and where do we get it from
ICS collects different types of personal data when you visit our websites. If you are a client, a prospective client or a partner of ICS, we may also process information about you even though you have not visited our websites.
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The information we collect may include contact information, e.g. name, email address, phone number, job title, company name and geographic area. We may also record information about your IP address or other device addresses, web browser and use of our websites. Information on your interaction with email messages may also be collected, such as whether you open, click on or forward a message.
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We will not process any special categories of data unless you provide them to us, and we ask you not to disclose any such data to us.
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The information about you may be collected when you visit our websites, fill in web forms, when we interact with you in person or via third parties, such as partners or third-party websites.
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2. How do we use your personal data
We use the information collected on our websites to operate, maintain, enhance and provide features on the websites, to provide the services and information you request, to understand and analyse the usage trends and preferences of our visitors, to improve the websites and to develop new features and functionality.
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We may use your email address to provide marketing information, including email marketing on product releases, webinars, events, latest announcements etc. To the extent that your consent is needed to allow us to send you such information, we will make sure to collect such consent from you before we send you any marketing information. Your personal information, such as job title and company name may be used to ensure we provide the most relevant content.
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If you are an employee of a client of ours, we may use your personal data in order to provide our services.
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We may also use your personal data for other purposes, including carrying out market research, surveys, profiling of prospective clients, marketing via other channels than emailing and to prevent and detect any misuse of our websites.
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If our processing of your personal data is subject to the EU General Data Protection Regulation (GDPR), the legal basis of our processing is GDPR article 6.1(b) (processing is necessary for the performance of a contract) or 6.1(f) that allows us to process your data to the extent that processing is necessary for the purposes of the legitimate interests pursued by us. Our legitimate interests are in maintaining attractive websites, maintaining contact with clients, prospective clients and partners, and managing events.
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Your personal data is only stored for the period necessary to fulfil the purposes mentioned above. Personal data processed for sending you email marketing will be kept until you opt out of receiving emails. Once you have opted out, your personal data will no longer be used for these purposes, although we may still keep it, if we have other legal grounds.
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3. Cookies Policy
Please go to our Cookie Policy to find information about our use of cookies.
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4. When does ICS disclose your personal data
ICS may share your personal data internally within the ICS Group or with certain third-party suppliers who help us carry out our marketing activities (e.g. operating the website, planning events, conducting surveys on our behalf and sending out invitations and email marketing).
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ICS will make sure to have agreements with such third parties that ensures protection of personal data. ICS will enter into data processing agreements that defines how personal data may be processed, what kind of security measures must be established by the supplier, and the confidentiality obligations imposed on the supplier. If personal data is transferred out of the EU, ICS will ensure that appropriate measures are taken to protect personal data in accordance with applicable data protection laws. This may be in the form of EU standard contractual clauses, binding corporate rules or the EU/US privacy shield.
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5. Security
ICS maintains appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction or damage, or other violation of the provisions of applicable law.
At ICS access to personal data is based on the principle that access to data should be restricted to those who have a legitimate need for the data and the principle that as few people as possible have access to such data. In other words, we operate on a need-to-know and nice-to-know principle. Only employees who have a need-to-know business need for personal data may gain access to such data.
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6. Your rights
If our processing of your personal data is subject to GDPR, you may contact us to receive information on the personal data processed about you. If any information processed is inaccurate, you have the right to get the information rectified. In certain situations, you may request to have information about you deleted.
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Please use the email address below if you want to contact us.
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7. Who is the data controller - and how to contact us
Investment Control Services Pty Ltd
Level 9, 60 Park St
Sydney 2000 NSW
Australia
is the data controller of any information we collect when you use our websites.
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If you are a client, a prospective client or a partner of one of our EU market units, the data controller may be that market unit. However, you can always contact ICS, and we will make sure to distribute your request to the relevant market unit, if applicable.
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Any questions, request for access etc. should be directed at the following email address: privacyenquiry@icsidm.com.
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8. Third Party Processors
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733.
You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.
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9. Updates of the policy
This policy may be updated from time to time. Please visit our website to see the most recent version.
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The current version was last updated March 2024.
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