Last updated on April 2018.
This website is operated by eSubstance Limited (trading as Ink). We are registered in England under company number 03829537 and our registered office is at Blackburn House, Blackburn Road, London NW6 1RZ. We are registered as a data controller with the Information Commissioner’s Office under registration number Z7993115.
For the purpose of the General Data Protection Regulation, we are the data controller.
1. What personal data do we collect from you?
In giving your consent, you acknowledge that we may collect and process the following information you provide:
1.1 your name, address, email address, phone number, age range, gender, details of employment, Internet Protocol (IP) address and any other information that you might choose to volunteer, that can be used to identify you, when you:
1.1.1 register with us and log in through the website;
1.1.2 place an order for products or services from us or enquire about advertising opportunities on the website;
1.1.3 subscribe to our RSS feed or to receive our newsletter or any other information from us;
1.1.4. complete enquiry forms on the website;
1.1.5 complete any voluntary surveys we may ask you to participate in from time to time;
1.1.6 submit comments or feedback for publication on the website or in any of our publications;
1.1.7 participate in any online forum which may be available on the website from time to time;
1.1.8 participate in any competition or prize draw that we may run on the website from time to time;
1.1.9 respond to our marketing communications;
1.1.10 correspond with us by phone, email or otherwise; or
1.1.11 report a problem with the website.
1.2 With your consent, the following Information may be automatically collected each time you visit the website:
1.2.1 technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
1.2.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
1.3 Information we receive from other sources, such as business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers.
2. How do we use your personal data?
2.1 With your consent, we use the information you give to us:
2.1.1 to improve our site and offering
2.1.2 to administer any account or registration you may have with us;
2.1.3 to carry out our obligations arising from any contracts entered into between you and us;
2.1.4 to provide you with the information, products and services that you request from us;
2.1.5 to administer your participation in any competitions or prize draws we may run from time to time;
2.1.6 to notify you about changes to the website or any other aspect of our service;
2.1.7 to communicate with you about any comments, queries or feedback you might have about us or the website;
2.1.8 for publication on the website or in our printed publications, but only if you have provided it to us for that purpose;
2.1.9 to ensure that content on the website is presented in the most effective manner for you and for your computer; and
2.1.10 to provide you with information about products and services we offer that we feel may interest you by post, telephone, SMS or email. We will send information only if: (i) you have consented to this; or (ii) the information is about products and services similar to those which were the subject of a previous sale or negotiation of a sale to you (and you have opted in to receive such marketing messages); or (iii) where we are permitted to do so by law without consent, for example, if you have provided us with a company email address. If you do not want us to use your information in this way, please contact us using our contact form below or using our contact details in paragraph 11 below).
2.2 We use the information about you that we collect automatically:
2.2.1. to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
2.2.2 to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
2.2.3 to allow you to participate in interactive features on the website, when you choose to do so;
2.2.4 as part of our efforts to keep the website safe and secure;
2.2.5 to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
2.2.6 to make suggestions and recommendations to you and other users of the website about goods or services that may interest you or them.
2.3 If we purchase information on you from a third party, such as marketing lists, we promise to take all necessary checks to make sure your information was collected legally. We will only use such information for the purposes set out above.
2.4 We do not use automated decision making (including profiling).
4.1 We do not knowingly collect information from individuals who are under the age of 16. If you are under the age of 16, please do not use or register with the website or provide any information about yourself to the website.
5. Disclosure of your information
5.1 We may share your information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
5.2 We may share your information with selected third parties including:
5.2.1 business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
5.2.2 advertisers and advertising networks that require anonymised data to select and serve relevant adverts to you and others. We may provide them with aggregate information about our users (for example, we may inform them that 100 women aged 18-24 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, men in a particular location). We may make use of the information we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
5.2.3 analytics and search engine providers that assist us in the improvement and optimisation of the website; and
5.2.4 credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
5.3 We may disclose your personal information to third parties:
5.3.1 in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
5.3.2 if eSubstance Limited (trading as Ink) or substantially all of the company’s assets are acquired by a third party, in which case personal data held by the company about our customers will be one of the transferred assets; or
5.3.3 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our various terms, policies and other agreements; or to protect the rights, property, or safety of eSubstance Limited (trading as Ink), our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6. User content
6.1 User content is any content submitted to us for the purpose of publication on the website (including in any public forum we may provide) or in our printed publications. All user content you submit will be treated as non-confidential and may be visible to other registered users as well as to unregistered visitors to the website, so please do not submit any information about yourself which you would not wish to make public. (For the avoidance of doubt, user content does not include any other correspondence between you and us.)
6.2 Once you have submitted user content to us, you may be unable to recall or delete it except in limited circumstances. If you are unable to edit or delete user content you have submitted, please refer to clause 9.1 and contact us through our contact form below or by using our contact details in paragraph 11 below.
6.3 We do our best to ensure that offensive language and content do not appear on the website, but we do not routinely monitor or moderate user content and therefore user content may from time to time include language or content which some people may find offensive. If you wish to complain about any user content, please contact us through our contact form below or using our contact details in paragraph 11 below.
7. Where we store your information
7.1 We have in place a level of security appropriate to the nature of the information stored and the harm that might result from a breach of security. All information that you send via the website is encrypted whilst in transit between you and the servers where we store the information. Your information is stored on the secure servers of our web services provider in Ireland.
7.2 Any payment transactions will be encrypted using SSL technology in such a way as to ensure that we are not given your financial or credit card information.
7.4 If you use our services while you are outside the EU, your information may be transferred outside the EEA in order to provide you with those services.
7.4 Unfortunately, the transmission of information via the internet is not completely secure and, although we will do our best to protect your information, we cannot guarantee the security of any of your information transmitted via the website. Consequently, any transmission is at your own risk. If we become aware that the security of your information has been compromised, we will notify you by email or as otherwise required by law.
7.5 In the event that a security breach does occur that could adversely affect you, and we have the means to let you know, we will take appropriate steps to notify you how the breach occurred, its nature, the steps we have taken to rectify the issue and the steps you can take to rectify any minimise any adverse impact.
7.6 Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential and you must not share it with anyone.
8. Links to third-party websites
8.2 We do not accept any responsibility or liability for third-party websites or their privacy policies and we strongly advise you to check such policies and the reputation of the website before you submit your information to any third-party website, the owners of which do not necessarily have any connection, commercial or otherwise, with us. We welcome any feedback about third-party websites linked to from the website.
9. Rights of individuals
9.1 The General Data Protection Regulation gives you the right to access, rectification or erasure of the personal data, data portability, restriction of processing, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory body. You can exercise the above rights by using our contact details in paragraph 11 below.
9.2 Our legal basis for processing your data is either consent or legitimate interest. You have the right to withdraw your consent at any time and ask us not to process your personal information for marketing purposes. You can exercise your right to prevent such processing at any time either through the unsubscribe link at the bottom of our marketing emails or by using our contact details in paragraph 11 below.
9.3 We will retain your data for the shortest period of (i) we have your consent, (ii) for a reasonable period of time for the purpose that it has been collected or (iii) as required by law.
11. Contacting us