IPS CLOUD PRIVACY POLICY

This Privacy Policy applies to app.ips.cloud and any other services that we may provide through our IPS Cloud application site (“our services”).

In the context of this Privacy Policy “personal information” means information which, on its own or in combination with other information, can be used to identify a natural person, in particular by reference to an identifier such as name, identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

This Privacy Policy governs how we may use or process personal information. It is important to understand that if you interact with IPS Cloud, it will be necessary for you to agree to be bound by the terms of our Acceptable Use, Privacy, Cookie and Retention Policies.

The personal information that you give us, or we receive or collect about you, will be processed under the UK Data Protection Act, 2018 (DPA) which embeds the EU General Data Protection Regulation (GDPR) into UK law.

Our respective roles determine whether we are a data processor or data controller for your personal information.

1. Where you have been provided with login credentials for IPS Cloud and interact with IPS Cloud as a Turnkey customer and subscriber to the IPS Cloud services, the Turnkey customer will be the data controller and Turnkey will be the data processor, as per the terms of our IPS Cloud Data Processing Agreement and the IPS Cloud Subscription Terms Agreement.
2. Where we collect personal information about you through your interactions with our site in general, for example, by collecting your IP address or placing cookies on your computer, then we will be the data controller for that personal information only. As the data controller in respect of this information, we can determine the purposes for which and the manner in which that personal information is, or may be, processed by us.

The remainder of this Privacy Policy primarily relates to data processing where Turnkey is the data controller, as described above.

How you consent to us collecting your personal information

When you visit app.ips.cloud for the first time you will be prompted to read and accept our Acceptable use, Privacy, Cookie and Retention Policies before you can continue.

By clicking or selecting the “I Agree” button on screen, you are confirming to us that you are freely giving us informed and specific consent for us to collect and process your personal information for the purposes specified in this Privacy Policy, and that you are accepting and consenting to the practices described.

Lawful Basis and IPS Cloud

Where we are a data processor, we strictly limit the processing, scope and use of personal data for the purposes of delivering the IPS Cloud Service as per our Data Processing Agreement with the Data Controller. The lawful basis for processing in this case is the responsibility of the Data Controller.

Where we are a data controller as described above, your explicit consent is the lawful basis for processing.

Information we may Collect

You may give us personal information about yourself by logging onto IPS Cloud. The information you may provide to us when you visit app.ips.cloud or report a problem, is listed below:-

IP Address, user name (email address) and browser type.

Information we may collect about you

When you use the IPS Cloud services, we may collect information about you including which features you have used (including date and time). and the data you have inserted and changed.

The purpose of this information is to allow us to administer IPS Cloud and for internal operations, including troubleshooting, data analysis, testing, research, improving our services to ensure that content is presented in the most effective manner for you and for your device, and as part of our efforts to keep our site safe and secure.

Where we store your personal information

The personal information that we collect from you will be stored within the United Kingdom.

Aside from Google Analytics as detailed below, we will not knowingly transfer your personal information outside of the European Economic Area.

IPS Cloud
IPS Cloud is hosted by our hosting partner EKCO (https://www.ek.co/)
EKCO’s datacentre is located in the United Kingdom.

Google Analytics
Where we use Google Analytics to collect personal information which helps us measure how users interact with the IPS Cloud services, then this personal information will be handled in accordance with our Cookie Policy and Google’s privacy policies and procedures.

This information may be transferred outside of the European Economic Area in accordance with Google’s policies.

All personal information you provide to us or we receive about you is stored on our secure servers. Where practical and reasonable we encrypt communication between our site and you using Secure Socket Layer/Transport Layer Security technology. We may also use encryption at rest and other technologies where reasonable to secure personal information.

Where we have given you (or where you have chosen) a password which enables you to access IPS Cloud, you are responsible for keeping this password strictly confidential and secure as per the terms of the IPS Cloud Subscription Agreement. This password must not be shared with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted from our site and any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorised access and we apply a “Privacy by Design” approach to our personal information handling and assessment procedures.

Your rights

Where we hold personal information about you as a data controller, you have a right to ask us to erase your personal information, which we will do in line with the requirements of the DPA.

Access to Information

You have the right to access a copy of the personal information that we hold about you, where we are the data controller.

We cannot release your personal information to anyone else. We can only release your personal information to you, or to an authorised third party who can demonstrate that you consented to have your personal information released – this is a legal requirement. Therefore, it is important for us to ensure that we confirm your identity before we can release any personal information.

Where we are a data processor, requests for personal information should be directed to the data controller.

How long will you hold onto my personal information?

Where we are a data controller, we will hold onto your personal information in accordance with our Retention Policy.

Changes to our Privacy Policy

We may need to change this Privacy Policy if it is necessary for legal reasons or to reflect changes to our services. The provisions of this Privacy Policy may be changed without prejudice to your rights. When we change our Privacy Policy we will make the updated Privacy Policy available on the IPS Cloud application site and we will also change the “Last Updated” date.

Once we change our Privacy Policy, it will become legally binding on you 30 days after we post it on our site. During that period you are welcome to contact us if you have questions about the changes.

Contact Information

IPS Cloud is operated by TURNKEY COMPUTER TECHNOLOGY LIMITED. We are registered in Scotland as a limited liability company, registered number SC072426, whose registered office is Thornton Lodge, East Kilbride Road, Glasgow, G76 9HW.

Turnkey Computer Technology Limited, Core Australia Pty Ltd and Turnkey Pty Ltd are wholly owned subsidiaries of Turnkey (Global) Limited.

To contact us please email data protection team at Turnkey HERE or call us on +44 (0)141 644 5444.