- ICS will be transparent about the information we are collecting and what we will do with
which include providing you with services you have requested with ICS.
- We will also use the information to help us understand you better and offer relevant and appropriate services.
- If you tell us you don’t want to receive marketing messages we will stop sending them. We will, of course, continue to send essential information relating to services we are performing for you to keep you informed.
- We will put in place measures to protect your information and keep it secure.
- We will respect your data protection rights and aim to give you control over your own information.
Custodian of Personal Information
ICS, Inc. is the “data controller” under applicable laws, including the United States, United Kingdom and the European Union. Our address is 8283 N. Hayden Road, Ste. 128, Scottsdale, Arizona, United States, 85258.
Personal information means details which identify you or could be used to identify you, such as your name, contact details and purchase history. It may also include information about how you use our websites and applications.
How can you keep your Personal Information Secure?
We take great care to protect the personal information you provide to us. You should take the following steps to ensure you keep your personal information secure. You should always keep your account information confidential from other 3rd parties. Giving your account information or log in may allow them to access your personal information through our systems. When you finish using our websites or applications you should log out if others are able to access your computer or device.
When do we collect personal information about you?
We collect personal information about you whenever you use our services, including when you use our website or applications, or interact with us via email or call our agents or call center.
What types of personal information do we collect?
When you make inquiries about or use our services, you will need to provide us with your personal details. We collect the following categories of personal information:
- Information you provide when you make an inquiry for services through our website, applications or to our agents or call center.
- Information about the services we have provided to you in the past.
- Information about online registration and other interactions.
- Information about your use of our website, applications, call center and applications.
- Information about your device and your location if you have been browsing on our websites or applications, for example your IP address or unique device ID. (An IP address (i.e. Internet Protocol address) is a numeric code that can act as a unique identifier for your computer or other device – this can be turned off from your device).
What do we use your personal information for?
The main purposes for which we use your personal information are:
- To fulfil and provide the services you have asked for
- To send updates and service communications to you.
- To provide services tailored to your requirements and to treat you in a more personal way.
- To carry out analysis and market research.
- To carry out marketing including online advertising and keep you informed of ICS services.
- To undertake targeted online advertising.
- To send you status updates and service communications.
- To improve our websites, products and services.
- For management and administrative purposes.
When will we send you marketing; opt-out procedure
When we collect information directly from you we may ask you if you do not want to receive our marketing communications. We will respect your choice as to what communications you wish to receive and how these are sent.
If you decide you would no longer like to be sent marketing communications, you can change your mind at any time. In addition, each marketing communication we send by email will also have an unsubscribe option which will allow you to stop you receiving further marketing emails. We aim to action requests to stop being sent marketing communications within 10 working days of receiving those requests, but it is possible you will receive some marketing in the period prior to that change being made. Please note that if you tell us that you do not wish to be sent further marketing communications, you will still receive service communications (as described above) which are necessary, for example, to perform services for you.
ICS will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reason or reasons ICS collected and needs to use your information. In the United States, United Kingdom and the European Union data protection laws in almost all cases the legal basis will be:
- Because we need to use your information so that we can process the services which you have requested.
- Because it is in ICS’s legitimate interests as an investigation agency to use your personal information to operate and improve our business within the industry.
- Because ICS needs to use your personal information to comply with a legal obligation.
- To protect the vital interests of you or another person.
- Because you have consented to ICS using your information for a particular purpose.
More information on each legal basis is provided below. If processing of your data is subject to any other laws, then the basis of processing your data may be different to that set out above and may in those circumstances be based on your consent in all cases.
How long do we keep personal information?
We will keep your information for as long as we need it for the purpose it is being processed for. We will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating to services. The information may also be retained so that we can continue to improve your experience with us. We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. If you stop interacting with us as a client, we will remove or anonymise your information after 7 years.
Performance of a Contract with you?
It will be necessary for ICS to use your personal information to complete services you have contracted with us. We have a legitimate business interest to use your personal information to comply with these contractual obligations. There are situations in which legal obligations require us to use your personal information to comply with said obligations. There are situations where we may need to use your personal information to protect the vital interests of you or another person.
We may collect and use your personal information where you have given specific consent to us doing so. If the basis of our processing your data is consent to marketing, you can withdraw your consent to such processing at any time, including by amending your account online. However, if you withdraw your full consent, in some circumstances, it may mean we will not be able to provide all or parts of the services you have requested from us and you will not be able to cancel your booking or obtain a refund of any charges you have paid.
What are your legal rights in relation to the personal information we hold about you?
Under data protection laws in the United States, United Kingdom and the European Union, you have certain rights in relation to your personal information. Responses to exercise your rights will be provided within one month and generally there is no fee for making these requests. If your request is particularly complicated we may extend the deadline for responding to three months, but we will let you know if this is the case.
We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise, and the nature of the personal information involved, there may be legal reasons why we cannot grant your request. Further explanation of those rights and the exceptions to them are set out below.
Your rights include the following:
- You may request us to stop sending you marketing. If you do so we will no longer be able to send you marketing communications. However, if you contact us we will need to send you communications about the services you have inquired about. These communications will help you get the most from the services we provide and may also contain options and other details about the services you will be using.
- You may request us to stop using your personal information where we are doing so under legitimate interests unless it is needed for dealing with legal claims or we have other compelling legitimate reasons that override your rights.
- You may request us to stop processing of your personal information for marketing purposes including analytics for the purposes of targeted marketing, including online advertising.
- You may access the personal information we hold on you. There are some limited exceptions to this right, such as information relating to others who have not consented to the disclosure of their information and information which is legally privileged.
- You may ask us to correct your personal information (the 'right of rectification’) if that information is inaccurate.
- You may ask for personal information which identifies you to be erased (or forgotten).
To do this we will remove the information that identifies you from the data we hold in our active systems (“anonymise”). However, a separate and restricted copy of the identifying information will be kept for 7 years to meet the obligations we have to law enforcement, national authorities and legal proceedings.
- We may need to retain certain elements that relate to a contract between you and ICS because we need it for our own legal and auditing purposes.
- In some circumstances it may mean we will not be able to provide all or parts of the services you have requested from us in relation to services.
- We cannot erase your personal information if we have identified that you either have an open complaint with us or we hold a previous case for you within the past 6 years. We are required to retain this information in case there is a need to re-open the complaint.
How can you change how we use your data?
If you wish to change how we use your personal information, please contact DPO@icsworld.com. We will ask for some information to identify you, which will only be used to process your request. We will verify your identify via email before processing your request.
If you wish to receive a copy of your information, you can make your request in writing and include the following information with your request:
- Your name and postal address
- Details of your request
- a photocopy of your passport or driving licence, so that we can verify your identity
- your signature and the date of the request
- if you are applying on behalf of another person then signed authority from the individual is required
Any details which may help us locate the information which is the subject of your request, including your Case Number. Requests via post can be mailed to:
Data Protection Officer
8283 N. Hayden Road, Ste. 128
Scottsdale, AZ 85258
How to get in touch with us and your right to complain?
If you have any questions about this policy, please contact the Data Protection Officer. The Data Protection Officer for ICS can be contacted at DPO@icsworld.com
We work hard to handle your information responsibly. If you are unhappy about the way we do this, please contact the ICS Data Protection Officer who will address your concerns. We hope that we will be able to resolve any concerns you may have.