IPE Global Limited and its subsidiaries -Triple Line Consulting Limited, United Kingdom; IPE Global (Africa) Limited, Kenya, IPE Centre for Knowledge and Development, Ajooni Impact Investment Advisors Private Limited- (collectively, the “IPE Group”) are privacy conscious global organizations. This means we are committed to protecting the privacy of all individuals who interact with us, whether by registering as a user on our websites in order to receive our data and reports, participating in one of our research projects, as a way of being a sub-contractor for our projects or by attending one of our events. This approach to privacy applies to all personal information received by us from our customers, whether in electronic, paper or verbal form.
This policy explains what personal data IPE Group holds about you, how we process it and how we use it.
It is important that you read this policy, together with any other privacy disclaimers we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
What personal information do we collect
We only collect the personal information which is relevant for the purpose for which it is sought and will not intrude into an unreasonable extent upon your personal affairs.
We may collect, store, and use following types of personal information, including, but are not limited to:
- The contact details you provide to us, including names, titles, addresses, telephone numbers and email addresses;
- Personal details/data such as gender, marital status, etc.
- Financial information, such as salary/remuneration.
- “Supplier Details” such as bank account numbers, tax identification numbers, registered addresses, passport information, etc.
How we collect your information
If you contact us (by telephone, e-mail, instant messenger or voice over IP) we will collect your personal data and process it in accordance with the processes outlined in this Policy. This may include discussing matters with you in relation to an enquiry about our services or a contract that we may enter into with you, or because you have subscribed to our newsletter or request a publication from us.
We typically collect your personal information through the RFP/any pre-contracting process, directly from you or individuals working for the sub-contractor/partner or from information which the sub-contractor/partner has made publicly available.
How we use your information
This Policy tells you what to expect when we collect your personal data.
We will only process your personal data if as notified to you at the time we collect your personal data, and for the purposes for which it was collected for, or unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose or we have a legal basis for doing so. If we need to use your personal data for an unrelated purpose, we will notify you prior to commencing that processing and we will explain the legal basis which allows us to do this. Please note that we may process your personal data without your knowledge or consent, where this is required and/or permitted by law.
Your personal data may be shared in accordance with our principles on transfers to third parties as set out later in this Policy, including (but not limited to) the following:
- any member of our Group, including our subsidiaries or holding companies.
- third parties where we are under a duty to disclose your personal data to comply with any legal obligation, or to appropriate regulators or other law enforcement organisations.
- third parties to whom we choose to sell, transfer, or merge parts of our business or our assets
- third party suppliers to us, including (for example) insurance providers, brokers, auditors and our IT providers.
If your personal data is to be shared with any other third parties, we will take steps to protect your personal data.
On what basis we process your personal data
We are not allowed to process your personal data unless we have a legal basis for doing so. There are four main legal bases that we rely on when it comes to processing someone personal data. These are:
- “Legitimate interest”: this is where we need to process your personal data, for example, if we need to contact you because you have raised a general query with us or where we are in contact with you about this or similar issues, or, in terms of your IP address and any information gathered via “cookies”, to aid your use and navigation of our website (https://www.ipeglobal.com) or any microsites or IPE Group links on our web. We may also have a legitimate interest to contact you about services that may be of interest to you as part of our marketing campaigns, in accordance with this Policy.
- “Necessary for performing a contract”: this is where if we are in a contract with you (or about to enter into a contract with you and you have requested certain pre-contract details) and we need to use your personal details to complete this contract – for example, we might need to use your e-mail address to communicate with you, which would count as processing your personal data or Supplier Details to create Supplier Code in our System.
- “Consent”: this is where we set out specific circumstances where we want to process your personal data and request your consent for this. We will make sure that your consent is explicit. We will usually ask you to tick a box (or similar) to confirm that you have provided your consent. For example, unless we have a legitimate interest to contact you about our services that we would like to market to you, then we would obtain your consent to market to you in the alternative. If you have any questions about the specific circumstances, please contact Vice President – Corporate Risk and Compliance, Mr. Sudarshan Panda. Please note that you can withdraw your consent at any point by contacting our Data Protection Officer for further information at firstname.lastname@example.org.
- “Compliance with a legal obligation: this is where we might need to process your personal data in order to comply with a common law or statutory obligation, such as disclosures for compliance with statutory requirements, requirements relating to money laundering or other such disclosures. We will only process your personal data for this reason if it is necessary and we would not otherwise be able to comply with that legal obligation without such processing.
Marketing: As mentioned above, we may market to you on the basis that we have legitimate interests to market our business and we may have identified the organization that you work for as a business that we would like to market to. We will therefore rely on legitimate interests as our legal basis for processing your personal data that may be connected to your organization’s contact records for this purpose, however we will balance this against your rights as a data subject and will no longer market to you if you wish to unsubscribe from receiving such marketing communications directly to your contact details. Alternatively, where we do not have a legitimate interest to market to you, then we will seek your consent to do so, which will then be our legal basis for contacting you in that way.
Access and accuracy of your data
To the extent that you do provide us with personal data, we wish to maintain accurate personal data. Where we collect personal data from you, we want to provide a means for you to contact us should you need to update or correct that information. If for any reason those means are unavailable or inaccessible, you may send updates and corrections about your personal data to email@example.com we will incorporate the changes to your personal data that we hold and try to do so as soon as practicable.
We are reliant on you to ensure that personal information you supply to us is true and accurate to the best of your knowledge.
How we decide to how long to retain your personal data
We cannot definitively set out how long we will retain all personal data in this Policy – this is a general notice that deals with different personal data collected for a variety of reasons. However, we decide how long we will retain your personal data based on the following factors:
- If we are performing a contract with you – for the length of that contract and for approximately 15 years afterward to deal with any post-contract issues.
- If you are in contact with us – we will retain your personal data as long as it is necessary for us to conclude the relevant correspondence with you.
- Whether we think there is a likelihood of you contacting us again in the near future or if we think we need to contact you again, provided that the legal basis (see above) for doing so still exists, for no longer than is necessary in respect of that legal basis.
Storage and security of personal information
Personal information is stored in written or electronic form on our servers and computers and in various physical locations.
We take reasonable steps to protect your personal information from misuse and loss, and unauthorised access, modification and disclosure, and any other interference. Personal information is destroyed, de-identified or archived when no longer required.
As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Visitors to our websites
When someone visits www.ipeglobal.com our main corporate website or any of our related microsites we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. We collect this information in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting any of our websites. We will not associate any data gathered from these sites with any personally identifying information from any source. If we do want to collect personally identifiable information through our website, we will make it clear when we collect it and explain what we intend to do with it.
Our Group websites contain links to external websites. Please note that we are not responsible for the privacy practices of any websites other than our own.
We use some functional cookies to help enhance the user experience. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Just so you know, the main cookies on your site are from Google Analytics tracking and there’s also a session cookie generated by our website that is essential to the running of the website but holds no personal data. We don’t allow Google to store or use our data.
Other tracking technologies: Some of our website pages utilize cookies and other tracking technologies. A cookie is a small text file that may be used, for example, to collect information about website activity. Some cookies and other technologies may serve to recall personal data previously indicated by a website user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re-enter your details to gain access to certain parts of the website.
You are entitled to request access to all personal information you have given us. You may make any changes you deem appropriate, including the removal of personal information that you do not want us to retain.
Changes to this Policy