Privacy Policy

Introduction

Northwest Innovations Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how Northwest Innovations Ltd looks after your personal data, and tell you about your privacy rights and how the law protects you:

• When you visit its website at https://id-screen.com, regardless of where you visit it from (“Site”),
• How your personal data is processed when providing our membership area for access to the Service when you become a Subscriber and make use of our Product.

It is important that you read this privacy policy together with any other privacy notices or fair processing notices Northwest Innovations Ltd may provide on specific occasions when it is collecting or processing personal data about you so that you are fully aware of how and why it is using your data. This privacy policy supplements any other notices and is not intended to override them.

Controller

Northwest Innovations Ltd is the controller and responsible for your personal data (referred to as “we,” “us” or “our” in this privacy notice). We are a company registered in England and Wales under company number 14425558. Our registered office is Northwest Innovations Limited, Bentley Suite, The Motorworks, Chestergate, Macclesfield, Cheshire, United Kingdom, SK11 6DU.

You can contact us:

• by post at: The UK Compliance Team,Northwest Innovations Limited, Bentley Suite, The Motorworks, Chestergate, Macclesfield, Cheshire, United Kingdom, SK11 6DU;
• by email at: support@id-screen.com

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

You can contact the DPO:

• by post at: Data Protection Officer,Northwest Innovations Limited, Bentley Suite, The Motorworks, Chestergate, Macclesfield, Cheshire, United Kingdom, SK11 6DU; or,
• by email at: dataprivacy@id-screen.co.uk

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed or where additional measures have been taken so that the identity of the user cannot be ascertained from its contents (anonymous data).

For holders of a ID Screen subscription, we will also process personal data in accordance with the Privacy Notice and terms and conditions applicable to the ID Screen subscription.

In particular, we may use information we hold about you:

• for the purposes of processing, providing you with and managing your ID Screen subscription;
• to collect payments when due (if applicable); and
• if you have agreed, either when purchasing or registering for a ID Screen subscription or during your subscription, to provide you with information about our products, promotions and exclusive offers provided by us or other members of our group of companies that we believe may be of interest to you. Depending on your selected preferences, such communication may occur by email or SMS.

Privacy Notice for General Use of the Website

When using the Site, whether you are a ID Screen Subscriber, Visitor or other Site user, we may collect and process the following data about you:

1. Information you give us.

This may include:

• contact details you may provide to support a query you raise using the ‘contact us’ form e.g., service queries or billing enquiry.
• login credentials such as email address and password used for accessing the Membership Area of the Site.

2. Information we automatically collect about you

This may include:

• technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, the type of device you are using to access the Site, resolution of the screen and operating system; and
• information about your visit such as whether you have visited the Site before and information collected through the use of data analytics’ tools, which is anonymized.

The Northwest Innovations Ltd Group collects statistical information such as the number of visitors to certain areas of the Site during a given period. This information is collected for statistical review only and it cannot be used to identify an individual user. Please see our Cookies’ policy for more details.

This Site is not intended for children and Northwest Innovations Ltd does not knowingly collect data relating to children.

3. If you fail to provide personal data

Where we need to collect and use personal information by law, or where you are accessing the Membership Area, and you fail to provide that information when requested, we may not be able to perform the contract for the ID Screen subscription. Where we need to collect and use your personal information in order to respond to a query you have raised through the ‘Contact Us’ form on the Site, and you fail to provide that information when requested, we may not be able to respond to you and/or action your request.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions You may submit personal data (such as your contact details) by filling in the ‘Contact Us’ form on the Site or by corresponding with us by phone, e-mail or otherwise
• Automated technologies or interactions As you interact with the Site, we may automatically collect technical data about your equipment, browsing actions and patterns. Depending on your cookies’ settings, our data analytics’ tools may collect information about your online activity on the Site, such as the web pages you visit, the links you click, and the searches you conduct on the Site Please see our Cookies’ Notice for more information.

5. Miscellaneous

Changes to the privacy notice and your duty to inform us of changes

We may change this privacy notice from time to time by updating this page. We will not necessarily bring changes or updates to your attention so please revisit this page periodically to re-read this privacy statement and to ensure you are aware of any changes when you visit the Site. If there are substantive changes, we may at our discretion bring those to your attention, for example, by a message posted on the landing page of the Site. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This Site may include links to third-party websites, which may include websites provided by other companies within the Northwest Innovations Ltd Group. Clicking on those links may allow these third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.

Privacy Notice for the Use of our Services and ID Screen Subscribers

When you subscribe, you are able to choose which of your personal data can be monitored. Once you have added this information, we will do a historical check against previously leaked and breached data. After that, the added credentials will be constantly monitored to detect new and future leaks. The Data that is displayed in the portal when you log in is masked to not reflect the full description of the information.

Our Service searches the Internet for possible breaches to your data, and if it is detected that your personal data is at risk or is suspected to be somewhere where it should not be, you will be informed in writing. The alert can, depending on your chosen way of contact, be sent out via email and/or as a text message.

We collect your personal data when you complete your registration and set up of your Account (as defined in the general terms and conditions), or when you add information to your Account.

1. Disclosures of your personal data

Service Providers

Your personal information will be made available to our authorized service providers and other companies within the Northwest Innovations Ltd Group that provide services to, and third-party suppliers which perform certain services on our behalf (e.g., providing IT support and maintenance, providing hosting services, providing online payment services and providing marketing services).

These service providers may have access to personal information needed to perform their functions on our behalf but are not permitted to share or to use such information for any other purpose. We require all third parties to respect the security of your personal information and to treat it in accordance with the law, and to enter into a Confidentiality agreement with us in respect to any information they receive.

Monitoring Services

For the correct functioning of your Membership Area (and other ID Screen features that you pay for), we will require the support of trusted partners or the outsourcing of technical support. Your Membership Area and monitoring features are indispensable for the efficient provision of our services to you. Hence, so that we can monitor breaches to your personal data to the best of our ability, looking for matches in as many websites as possible, it is imperative that we use external Monitoring services provided by trusted partners. The below is a non-exhaustive list of the main functions for which we rely on the support of external partners, with a description of how customer data is handled at each stage:

1. Surveillance: When you add a “surveillance object” (for example, your mobile number) to your portal, this object becomes linked to your customer reference ID. The surveillance object is then masked and hashed before being stored by us or by external monitoring partners. For your safety, all data will be fully anonymized and encrypted which means that no one will be able to see what data you enter. This includes any person that is a member of our technical team or outsourced technical and monitoring support.

1. Monitoring: When a potential threat is detected, the hashed value (without personally identifiable data) of the surveillance object is matched with potential breached data collected by external Monitoring services.
2. Restoring: If there has been a match between your surveillance object and a data breach, you will receive an alert via your preferred method to receive your alerts. The existence of said match will be detected by us or by external monitoring partners, depending on where said match has been found. As part of your subscription, we will then provide you with suggestions on restoring your data after the breach.

We only make use and store only data that is strictly needed to provide you with the services. The same applies to any data anonymized and analyzed by monitoring partners. For monitoring purposes, if this is part of your subscription, any sensitive data such as bank details or credit card details are hashed to a non-reversible hash in accordance with the Payment Card Industry Data Security Standards, for which ID Screen holds certifications issued by the PCI Security Standards Council.

Other companies within the Northwest Innovations Ltd Group

We may share limited personal information with other companies within the Northwest Innovations Ltd e.g., to the extent needed for proper management and parental analysis and decision making.

Other Organizations

We may also disclose your personal information:

• In response to a court order, or a request for cooperation from a law enforcement or other government agency;
• To establish or exercise our legal rights; to defend legal claims; or as otherwise required or permitted by applicable laws and/or regulations;
• When we believe that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding illegal activity, suspected fraud, or other wrongdoing; to protect and defend the rights, property or safety of Northwest Innovations Ltd, other Northwest Innovations Ltd Group members, customers, staff, suppliers or others; to comply with applicable law or cooperate with law enforcement; or to enforce our terms or other agreements;
• To prospective or actual buyers in the event that we sell any of our business or assets, or to other Northwest Innovations Ltd Group members in the event of a reorganization.

We will not otherwise transfer, disclose, sell, distribute, or lease your personal information to third parties unless we have your permission to do so or are otherwise required or permitted to do so by law.

2. Purposes for which we will use your personal data

The table below describes our treatment of your personal data, collected on the Site. We also identity which of the lawful basis we rely on to do so and what our legitimate interests are.

Purpose/Activity	Lawful basis for processing including basis of legitimate interest
To make decisions on your Subscription.  Northwest Innovations Ltd does not envisage that any decisions will be taken about you using automated means, however Northwest Innovations Ltd will notify you in writing if this position changes	Performance of the contract for the ID Screen Subscription
To process, provide you with and manage your Subscription and provide ID Screen Services	Performance of the contract for the ID Screen Subscription
To communicate with you by e-mail, telephone or post if you have purchased ID Screen from Northwest Innovations Ltd, either regarding the purchase or other matters regarding transactions between you and Northwest Innovations Ltd or your customer relationship with Northwest Innovations Ltd	Performance of the contract for the ID Screen Subscription
To administer the Membership Area	Performance of the contract for the ID Screen Subscription
To contact you regarding any specific inquiry you make	Performance of the contract for the ID Screen Subscription
To collect payments when due	Performance of the contract for the ID Screen Subscription
Internal record keeping	(a) Necessary for Northwest Innovations Ltd ’s legitimate interests (for running our business) (b)  Necessary to comply with a legal obligation
To improve its products and services	Necessary for Northwest Innovations Ltd ’s legitimate interests (to develop its business and inform its marketing strategy)
Statistical analysis	Necessary for Northwest Innovations Ltd ’s legitimate interests (to study statistical trends within the business, to develop its business and inform its marketing strategy)
Fraud prevention	Necessary to comply with a legal obligation
Debt collection	Necessary for Northwest Innovations Ltd ’s legitimate interests (to recover debts due to it)
To contact you by e-mail, telephone or post in order to share information with you about products, services and events from Northwest Innovations Ltd and other members of the Northwest Innovations Ltd Group that may be of interest to you	Only where you have consented to this.
To contact you for market research purposes, if you have not objected to such use	Necessary for Northwest Innovations Ltd ’s legitimate interests (to understand whether customers value their product, to help it provide a better service to you, and to develop and improve its products and services)
To provide you with access to the Membership Area if applicable	(a) Performance of the contract for the ID Screen subscription (b) Necessary for our legitimate interests (for running our business, to develop our business)
Internal record keeping	Necessary for our legitimate interests (for running our business) (b) Necessary to comply with a legal obligation
To improve our products and services	Necessary for our legitimate interests (to develop our business and inform our marketing strategy)
Statistical analysis	Necessary for our legitimate interests (to study statistical trends within the business, to develop our business and inform our marketing strategy)

 

3. International transfers

So that we can provide and maintain our Service, your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be accessed by and transferred to — and/or stored on — computers and by staff located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Despite any differences in the regional or national laws, we will, in all circumstances, safeguard personal data as set out in this Privacy Policy.

Should we have to transfer personal data from the European Economic Area to a country outside the EEA (or a country that is NOT considered as offering an adequate level of protection as adopted by the European Commission, Art. 45 of the GDPR), additional measures will be in place to safeguard the relevant personal data. Such transfer will be based on legal grounds and mechanisms justifying such transfer, such as EU Commission-approved standard contractual clauses, or other legal grounds permitted by applicable law, unless exempted by an adequacy decision (http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm). We also rely on Your consent to this Privacy Policy followed by Your submission of such information as form of agreement to that transfer. Please contact our Data Protection Officer on the contact details set out in section 1 of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

4. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We align and adhere to applicable industry standards i.e., Payment Card Industry Data Security Standard (PCI DSS), demonstrating how we effectively secure your data when we process, store and transmit this information on behalf of our customers and business partners. We are continually reviewing and updating our security procedures as new technologies become available. All areas of the ID Screen website where personal information is collected are secure and your browser will display the ‘padlock’ symbol for reassurance. Where information is transferred it will be encrypted.

As you will know, the transmission of information via the internet is not completely secure, nor can it be guaranteed in every instance. The security of your Personal Data is important to us, and we maintain commercially reasonable physical, electronic, and procedural safeguards to protect your personal data in accordance with data protection legislative requirements. However, you are responsible for keeping your password and login details confidential and for complying with any other security procedures that we notify you of.

5. Data retention

How long will you use my personal data for?

We will retain your personal information collected on the Site for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law. Where you have a ID Screen subscription please see the Privacy Notice contained within your ID Screen Terms for a description of how long we will retain your data.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies’ Policy.

6. Your legal rights

Following the provisions of the General Data Protection Act (“GDPR”), 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 information we hold about you corrected. If you think that any information, we have about you is incorrect or incomplete, please contact us as soon as you can using the contact details set out below. We will correct or update any information as soon as possible.
• 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 information 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 information 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.
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, you can contact us:

• by post at: Data Protection Officer,Northwest Innovations Limited, Bentley Suite, The Motorworks, Chestergate, Macclesfield, Cheshire, United Kingdom, SK11 6DU.
• by email at: dataprivacy@id-screen.co.uk

We may need to request specific information from you to help confirm your identity and ensure your right to access the 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 will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

You also 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.