IWANA

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Privacy Policy

This website (and any mobile site or applications that link to this privacy policy) (collectively, the “Sites”) is owned and operated by IWANA CONSULTANCY SOLUTIONS (“IWANA CONSULTANCY SOLUTIONS,” “we,” “our,” and “us”). Data privacy is important to IWANA CONSULTANCY SOLUTIONS and upholding your trust is our priority. This privacy policy explains how we collect and use personal data obtained through the Sites and other means such as email, in person, or from other third-party sources.

Contacting us

If you have any questions about our privacy policy or your information, or to exercise any of your rights as described in this privacy policy or under data protection laws, you can contact us:

By post: Iwana Consultancy Solutions, 209, Om Sai wing, MK Gabino complex, off Ceaser road, Amboli, Andheri West, Mumbai – 400058

By email: info@iwanaglobal.com

Data protection principles

When processing your personal data, IWANA CONSULTANCY SOLUTIONS adheres to the following principles:

  1. Lawfulness, fairness, and transparency – data must be processed lawfully, fairly, and in a transparent manner
  2. Purpose limitation– data must be collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes
  3. Data minimization– data must be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed
  4. Accuracy– data must be accurate and, where necessary, kept up to date
  5. Storage limitation– data must be kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed
  6. Integrity and confidentiality– data must be processed in a manner that ensures appropriate security of personal data—including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage—by using appropriate technical or organizational measures
 

Personal data we collect

To aid business operations and marketing, IWANA CONSULTANCY SOLUTIONS collects and processes information pertaining to a research panel, client, and other contact details. This information may include the following:

  • your name;
  • home address;
  • contact details (such as telephone number and email address);
  • date of birth;
  • gender;
  • marital status;
  • copies of passport, driving license, and similar documents; and
  • educational history, training, and professional experience.
 

Information you give us

You may provide us with information over the phone, email, or otherwise, when you:

  • request information or materials regarding our services or ask us to contact you;
  • complete any of our online forms—for example, when you complete the “Get in Touch” online forms; and
  • make any comment or contribution on our Sites.

Applicants for employment

We may also collect personal information from you when you apply for a job with us through our careers page or respond to a specific listed employment position with us.

This information may include your contact information, curriculum vitae, previous work experience, education, transcript, driver’s license information, social security number or national identification number, and information relating to references.

Information we collect online

When you interact with us online, we employ cookies and other technological tools to gather information about your device and your use of our Sites, such as IP address, referring website, pages visited on your device, and the time you visited our Sites on your device. We will use the assembled information:

  • to manage our Sites and for internal operations, including troubleshooting, data analysis, testing, research, and statistical and survey purposes;
  • to improve our Sites to ensure that content is presented in the most effective manner for you and for your computer; and
  • as part of our efforts to keep our Sites protected.
 

Information we collect from third parties

We directly collect most of this information from you. In addition, we receive information about you when you use any of the other websites we operate or avail of the other services we provide.

We also work closely with third parties (including, for example, business partners; subcontractors in technical, payment, and delivery services; analytics providers; search information providers; and credit reference agencies) and may receive information about you from them.

We also collect information about you:

  • from publicly accessible sources, e.g., Companies House;
  • from third-party sources of information, e.g., client due diligence providers;
  • which you have made public on websites associated with you or your company or on social media platforms such as LinkedIn; and
  • from a third party, e.g., a person who has introduced you to us or other professionals (such as accountants) you may engage.
 

Sensitive personal data

We do not generally seek to collect sensitive personal data through our Sites. Sensitive personal data is information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health or sex life, sexual orientation, and genetic data or biometric data. If we do collect sensitive personal data, we will request your explicit consent to our proposed use of that data at the time of collection.

Children

The Sites are not intended for, or directed at, children under the age of 16 years and we do not knowingly collect data relating to children under this age.

What we do with your personal data

The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is explained below.

Purposes for which we will process the information

Legal basis for the processing

To enter into and perform contracts with you

It is necessary for us to process your personal data in this way in order to enter into a contract with you and to fulfill our contractual obligations to you.

To provide you with information and services that you request from us

It is in our legitimate interest to respond to your queries and provide any information requested in order to generate and develop business. To ensure we offer a good and responsive service, we consider this use to be proportionate and will not be prejudicial or detrimental to you.

To enforce the terms and conditions and any contracts entered into with you

It is in our legitimate interest to enforce our terms and conditions of service. We consider this use to be proportionate and necessary for our legitimate interests.

To populate our database intended for marketing purposes

It is in our legitimate interest to market our services. We endeavor to ensure that the contacts in our database are relevant and up-to-date. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

You can always opt out of receiving direct marketing-related email communications or text messages by following the unsubscribe link.

To send you publications, event information, and marketing communications

It is in our legitimate interest to market our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

For direct marketing sent by email to new contacts (i.e., individuals whom we have not previously engaged with), we will need your consent to send you unsolicited direct marketing.

To send you information regarding changes to our policies, other terms and conditions, and other administrative information

It is in our legitimate interest to ensure that any changes to our policies and other terms are communicated to you. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.

·         To administer our Sites, including troubleshooting, data analysis, testing, research, and statistical and survey purposes

·         To improve our Sites to ensure that consent is presented in the most effective manner for you and your computer, mobile device, or other item of hardware through which you access the Sites

·         To keep our Sites protected

For all these categories, it is in our legitimate interest to continually monitor and improve our services and your experience of the Sites and to ensure network security. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.

To measure or understand the effectiveness of any marketing we provide to you and others and to deliver relevant marketing to you

It is in our legitimate interest to continually improve our offering and develop our business. We consider this use to be necessary in order to effectively generate business and will not be prejudicial or detrimental to you.

For normal business purposes such as payment processing and financial account management, product development, contract management, website administration, fulfillment, analytics, fraud prevention, corporate governance, reporting, and legal compliance

It is necessary for us to process your personal data in this way in order to enter into a contract with you and to fulfill our contractual obligations to you.

Where we rely on legitimate interests as a lawful basis, we will carry out a balancing test to ensure that your interests, rights, and freedoms do not override our legitimate interests.

If you do not wish to provide us with your personal data and processing such information is necessary for the performance of a contract with you, we may not be able to perform our obligations under the contract between us.

IWANA CONSULTANCY SOLUTIONS will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you in a timely manner and will explain the legal basis that allows us to do so.

Email marketing

For email marketing to an individual subscriber (that is, a noncorporate email address) with whom we have not previously engaged as a client, we will need your consent to send you unsolicited email marketing.

Where you provide consent, you can withdraw your consent at any time, but without affecting the lawfulness of processing based on consent before its withdrawal.

You have the right to opt out of receiving email marketing communications from us at any time by:

  • contacting us using the contact details provided above; or
  • using the “unsubscribe” link in emails.
 

Disclosure of your personal data to third parties

IWANA CONSULTANCY SOLUTIONS will share such information with its consultants, contractors, affiliates, and advisers as necessary to carry out the purposes for which the information was supplied or collected.

Personal data will also be shared with our third-party service providers who assist with the running of our Sites and services, including marketing, database service providers, IT services such as backup and disaster recovery service providers, and others. Our third-party service providers are subject to security and confidentiality obligations and are only permitted to process your personal data for specified purposes and in accordance with our instructions.

In addition, IWANA CONSULTANCY SOLUTIONS will disclose information about you:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
  • if all or substantially all of IWANA CONSULTANCY SOLUTIONS’s assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal information in order to comply with any legal obligation;
  • if necessary to protect the vital interests of a person; and
  • to establish, exercise, or defend the rights of IWANA CONSULTANCY SOLUTIONS, our staff, clients, or others.

Please note that we may also disclose information about you that is not personally identifiable; for example, we may publish reports that contain aggregated and statistical data about our customers’ products. These reports do not contain any information that would enable the recipient to contact, locate, or identify you.

International transfers

IWANA CONSULTANCY SOLUTIONS operates with staff, vendors, and offices in many countries around the globe. The personal data and professional information you provide to IWANA CONSULTANCY SOLUTIONS may be processed, transferred, and shared with individuals in different countries for the purpose of routine business uses.

Security of your personal data

IWANA CONSULTANCY SOLUTIONS uses appropriate technical and organizational safeguards to protect personal data, both online and offline, from unauthorized use, loss, or destruction. We use industry standard physical and procedural security measures to protect information from the point of collection to the point of destruction. This includes encryption, firewalls, access controls, policies, and other procedures to protect information from unauthorized access.

Only authorized personnel and third-party service providers are permitted access to personal data, and that access is by need. Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent the unauthorized disclosure of personal data.

Despite these precautions, however, IWANA CONSULTANCY SOLUTIONS cannot guarantee the security of information transmitted over the Internet or that unauthorized persons will not obtain access to personal data. In the event of a data breach, IWANA CONSULTANCY SOLUTIONS has introduced procedures to deal with any suspected breach and will notify you and any applicable regulator of a breach where required to do so.

How long we keep your personal data

Your personal data will not be kept for longer than is necessary for the purposes for which it was collected and processed.

The following are the criteria used for retaining your personal data:

  • General queries and correspondence– when you make an enquiry or contact us by email or telephone, we will retain your information for as long as necessary to respond to your queries. After this period, we will not hold your personal data for longer than one year if we have not had any active subsequent contact with you;
  • Direct marketing– where we hold your personal data in our database for direct marketing purposes, we will retain your data for no longer than two years if we have not had any active subsequent contact with you.
  • Legal and regulatory requirements– we may need to retain personal data for up to 7 years, where necessary, to comply with our legal obligations, resolve disputes, or enforce our terms and conditions.
 

Your rights

Access to and updating your personal data

You have the right to access information that we hold about you (“data subject access request”). You also have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another data controller (“data portability”).

We want to ensure that your personal information is accurate and up-to-date. You may ask us to correct or remove information you think is inaccurate. Please keep us informed if your personal data changes during your relationship with us.

Right to object

Direct marketing

You have the right to object at any time to our processing of your personal information for direct marketing purposes.

Where we process your information based on our legitimate interests

You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information that is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing that will override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

Your other rights

Under data protection laws, you have the right to request that we rectify your personal information that is inaccurate or incomplete.

In certain circumstances, you have the right to:

  • request the erasure of your personal information (“right to be forgotten”); and
  • restrict the processing of your personal information to processing in certain circumstances.

Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.

Exercising your rights

You can exercise any of your rights as described in this privacy policy and under data protection laws by contacting us as provided in the “Contacting us” section above.

Save as described in this privacy policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested or (b) refuse to act on the request.

Where we have reasonable doubts concerning the identity of the person making the request, we may ask for additional information that is necessary to confirm your identity.

Links

From time to time, the Sites may contain links to and from the websites of our partner networks, advertisers, and affiliates.

If you follow a link to any of these websites, please note that these websites have their own privacy policies and IWANA CONSULTANCY SOLUTIONS does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

Complaints

If you have any questions or complaints regarding our privacy policy or practices, please contact us as provided in the “Contacting us” section above.

Changes to our privacy policy

We will only use your personal information in the manner described in this privacy policy. However, we reserve the right to change the terms of this policy at any time by posting revisions to our Sites.

If we make any material changes to this policy, we will place a prominent notice on our Sites.

At any point, if we decide to use personal information in a manner different from that stated at the time it was collected, you will be given a choice to allow or disallow any additional uses or disclosures of your personal information beyond that which was stated in this policy at the time your information was collected.

This privacy policy was last updated on 15 January 2024.