Privacy Policy

About Us

Imabi Ltd is owned and operated by the founder of Sarax Ltd and associated members. Sarax Ltd is a highly reputable organisation known for developing innovative solutions for UK police forces, the wider criminal justice community, and other government departments.

Using expertise developed from working with law enforcement, communications and digital solution specialists; Imabi Ltd has developed a personal safety App specifically aimed at schools, businesses and private individuals.

Imabi Ltd is registered as a data controller with the Information Commissioners Office reg number ZB028232.

Imabi company address is:

Zenza

Thibet Road

Sandhurst

Berkshire

GU47 9AR

Our commitment to data security

Imabi Ltd recognises the importance of respecting and protecting your personal data (information), whilst providing you with a range of quality services. To do so we need to collect, process, and share a certain amount of information about you.

This document explains what information we’re likely to hold, how we collect it, and how we will use or share it. It also explains your rights, and how to contact us or the UK regulatory authority should you wish to exercise your rights or make a complaint. We will treat your personal data fairly and legally and always with discretion and respect.

This policy applies to all your information however captured, including from our App, through our website, or via telephone conversations with our staff. This includes when you:

  • visit the Imabi Ltd website or link to this Privacy Policy
  • visit our branded social media pages
  • use the Imabi platform as a private account holder
  • use the Imabi  platform and associated services (the “App”) as an authorised user, for example, as a pupil or employee of one of our customers who provided you with access to our services
  • communicate with our offices or contact our operational teams via phone or email, or otherwise receive communications from us
  • register for, attend and/or otherwise take part in our events, webinars or campaigns

When pupils or employees use the Imabi4Education or the Imabi4Business Apps we are acting as the data processor of that information. This means schools and businesses who use our App and offer it to their pupils or employees remain in control of how we process that personal information. As controllers of the data, they are obligated to comply with all relevant data protection legislation regarding the data they collect, and what they share. In exercising their legal responsibilities, they put in place a contract called a data protection agreement which includes terms for Imabi Ltd to follow. The relevant organisation will also publish its own privacy policy, which will explain the reasons and legal bases to processing that personal information.

As a private customer you will need to enter into a contract with us before you can access our App and services. In these circumstances Imabi will determine the purpose for collecting your data as well as its use. In these circumstances we are controllers of your data with a legal responsibility to process your data transparently, lawfully and with integrity as outlined in this policy.

As we evolve and develop our App we may look to users who are willing to participate in that evolutionary process. This is to assist us to enhance the App by expanding its functionality and ease of use before making it more widely available. We will work closely with private customers, schools and business to assist in identifying volunteers to participate with our development programmes. We will only enrol you as a volunteer with your full consent.

The data we collect

If you are using the App as a service offered by your school or employer, the information we require is limited to your name and email address. This will enable you to set up your own account to access our services. Our App for schools includes innovative functionality, it enables you to create your own free text and structured reports to send back to your school. We do not routinely access or process the contents of your personal reports. We treat this information with the utmost confidence, recognising it is a private communication between you and the recipient nominated by your school.  The only exception might be if were necessary for us, or a third party acting under our control, to resolve technical issues or install system upgrades.

If you are a private customer, we will limit the personal information we collect. This means we will only collect the information we require to set up your user account and personal profile. This will include:

·      Full name ·      Postal Address ·      Age ·      Mobile Phone Number ·      Email address ·      Financial Information

Using Our Website.

We have published a separate privacy policy specifically setting out how we use your data when accessing our website. (Add a link or layer or use tiles for each policy).

Sensitive data

Imabi does not process sensitive data, known as “special category data” in data protection legislation. As part of its reporting function, the Imabi4Education App provides custom text fields in which sensitive data may be added by either you or your school. We do not access this data unless it’s necessary to resolve a technical issue. We recommend that you or your school do not add sensitive data to these fields. Any data entered into these fields is intended to be accessed and used only by the school who will exercise control over its contents.

Children

Our App is designed with the best interests of its users in mind, particularly children. It provides accurate and timely information directly to their smartphone or tablet, assisting individuals to make important lifestyle decisions on matters of personal wellbeing and safety.  We and our Clients follow the Children’s Code; a code of practice published by the Information Commissioners Office. (Add link to code or add a copy as a tile to the website)

If you are a pupil and your school has given you the option to use our App, they will apply the codes of practice to determine if use of the App is in your best interest and will have exercised a risk-based approach to ensure each child has reached an appropriate age and capability to use the App without compromising their rights or freedoms.

If you are a private customer between the age of 10 and 12 years, defined as transitional years by the UK regulator, we require the consent of a parent or guardian before a contract can be agreed.

We have provided a summary of this privacy policy made suitable for children 10 and above in Appendix A.

How we keep your information safe
We fully understand the importance and duty we have in protecting your privacy. We take appropriate organisational and technical steps to safeguard it whilst it’s in our care. This includes:
·      Restricting access to only those who require it
·      Proportionate technical preventative solutions are installed on our systems
·      Using encrypted computers
·      Ensuring our staff are trained and understand potential risks
·      By using adequate technical and physical security solutions
·      When transferring data to a third party, sending it securely using encryption or password protection, or a reliable secure courier
·      When taking files and records off site for business purposes
·      When deleting or destroying records or dispensing with IT equipment
·      By applying robust technical and physical security solutions
 
International transfers

The data that we collect from you is stored and hosted in the European Economic Area (“EEA”). Following Brexit in June 21, the UK has been deemed adequate in terms of EU data protection legislation, therefore many of the GDPR rules still apply. Occasionally, we may need to process your personal data outside the EEA, for example, where it is processed by staff operating outside the EEA who work for one of our suppliers. These transfers are subject to special rules under European and UK data protection law because non-EEA countries may not have the same data protection laws. If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by making sure at least one of the following safeguards is implemented:

  • We will only transfer your data to such third-party suppliers who have agreed to comply with the required data security standards, policies and procedures and have put adequate security measures in place
  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and the UK
  • Where we use certain service providers, we will use standard data protection contract clauses which have been approved by the European Commission. These are designed to re-create data protections equivalent to those we enjoy in the EEA and in the UK

How long do we keep your data.

Where we process personal data for site security purposes, we generally retain it for 12 months. 

If you are using either Imabi4Education or Imabi4Business we will retain your data for one year after you have closed your account with us.

Where we process personal data under a contractual arrangement with you we generally keep the data for 6 years from your last interaction with us.   

We may also keep personal information for longer periods where we are required to do so for legal or regulatory reasons, such as tax and accounting. 

Your rights

You have the right to access your personal data, and any such requests made to us shall be dealt within the legal time limits set. 

Your rights include:

·      The right to be informed about the collection and use of your personal data. This is a key transparency requirement of the GDPR ·      The right to access information held about you ·      The right to have inaccurate personal data rectified or completed if incomplete ·      The right to have personal data erased ·      The right to request the restriction or suppression of the processing of your personal data ·      The right to data portability ·      The right to object to the processing of their personal data in certain circumstances ·      Rights in relation to automated decision making and profiling

You also have the right to lodge a complaint with the Information Commissioner Office who can be contacted via their web site www.ico.org.uk

GDPR does not insist for requests to be made in writing, however it will enable us to manage your request more quickly if you were to use either email or letter, accompanied by some form of identification, such as a copy of a passport or driving license. Your request should be directed to:

GDPR@imabi.com

In most circumstances charges will not be made. Information will be provided promptly and no later than 30 days following receipt of the request.

Changes to this privacy notice

Our privacy notice is reviewed at least every 12 months. This privacy notice was last updated on 23rd September 2021.

How to contact us

If you want to request information about this privacy notice you can email us at GDPR@imabi.com

or write to us at

Zenza

Thibet Road

Sandhurst

Berkshire

GU47 9AR

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Appendix A                              Child Friendly Privacy Policy

Who are we?

Imabi Ltd is a company who creates Apps to improve individuals’ safety and to keep them informed. We work closely with your school to provide this service to you or other pupils at your school who want to use it.

What is personal data?

It’s information about you, for example - your name, where you live, your email address and details of the smartphone you use.

Why are we using it?

To enable us to offer you all the helpful services provided on our App Imabi4Education.

Where do we get it from?

Your school provides us with your name and email address only.

What do we use it for?

We need your personal information to set up an account for you to use, only if you decide to do so.

Where do we keep your data?

We process your information on our own systems, and on the systems used by other companies contracted to help us provide information to you on the App.

How long do we keep it for?

For as long as you remain a pupil at the school and want to use the App. You can cancel your account at any time.

Do you have to do anything?

No, we let you your school, and your parents or carers know how we are using your data in our privacy policy. If you want to find out more then contact your school or contact us at GDPR@Imabi.com

How do you control the use of your data?

The law gives us all rights to control what companies do with their personal information. You have the same rights as grown-ups: your right to know what data we have about you, the right to correct anything that’s wrong and much more. We also work with a data protection officer to make sure that we look after your data properly.

If you want to know more?

Contact ( add name or role of the appointed school contact) or us at GDPR@Imabi.com