Privacy Policy

IMAGE ANALYZER - PRIVACY NOTICE

• ABOUT THIS NOTICE
  • Image Analyser Limited is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law. Please read it carefully.
  • Data protection law says that the personal information we hold about you must be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely
  • If you have any questions about this notice or how we collect and use personal information about you please contact us.
• INFORMATION ABOUT US
  • We are Image Analyser Limited. Our registered office is at Towngate House, 2-8 Parkstone Road, Poole, Dorset, BH15 2PW. Our registered company number is 14474879 (referred to “we”, “us”, “our” throughout this private notice).
  • If you have any questions, our contact details are:
    • Image Analyser Limited, Towngate House, 2-8 Parkstone Road, Poole, Dorset, BH15 2PW
    • info@image-analyzer.com.
  • OUR BUSINESS
    • We develop software applications for our customers – being businesses, organisations and educational institutions (including universities, colleges and schools).
    • Our software applications are deployed by our customers to keep their technology systems secure and to monitor the websites and content accessed on their technology systems to ensure it is appropriate.
  • DATA WE COLLECT

Personal Data

• We will collect personal data about various users of our services. Please see “Types of People” below for further details.
• Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, which is anonymous data.

Types of People

• We collect personal data about the following types of people:

(a)  Business Customers- individuals who work at organisations who are customers of ours (e.g. businesses and educational institutions).

(b)  Business Users – individuals who work for our customers and use our software applications during their work activities.

(c)   Software Vendors- individuals who work at organisations (e.g. resellers/distributors) who we seek to sell our products to customers through

(d)  Children – children who attend a school which is a customer of ours and will use our software application through their educational activities.

(e)  Website Visitor- a visitor to our website who come to view our products and services, including filling out our contact form.

(f)   General Public – individual members of the general public (available publicly on the internet) whose photos/images have been highlighted by our software applications and uploaded to our moderation platform for security and threat verification. We will not be provided with photos/images of the general public which are on private secure areas of the internet.

Types of Personal Data

• We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

(a)  Identity Data - includes title, first name, maiden name, last name, image or photo.

(b)  Contact Data - includes billing address, delivery address, email address and telephone numbers.

(c)   Transaction Data - includes details about transactions (completed or in process), payment amounts/dates to and from you and other details of products and services you have purchased from us.

(d)  Website Data - includes information about how you use our website, which includes internet protocol (IP) address, browser type and version, time zone setting and location.

(e)  Marketing and Communications Data - includes your preferences in receiving marketing from us and our third parties and your communication preferences.

(f)   Usage Data – includes data collected through use of our software products by Business Users and Children which will include (i) websites visited, submitted or searched for, (ii) videos/photos or similar content viewed, submitted or searched for.

(g)  Output & Eror Data – includes data collected regarding outputs of our services and errors.

Aggregated Data

• We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Website Data to calculate the percentage of users accessing a specific website page or demo.

Special Categories of Personal Data

• We do not actively collect any Special Categories of Personal Data.
• We may from time to time, through the provision of our software application to customers, be provided with photos/images that allow us to infer a member of the general public’s race, ethnicity or religion. However, we will only use this personal data to provide our web security and monitoring software and services to our customers.
• Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We do not collect any information about criminal convictions and offences.

If you fail to provide personal data

• Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

• HOW IS YOUR PERSONAL DATA COLLECTED?
  • We use different methods to collect data from and about you including through:
• Direct interactions.

You may give us your Identity and Contact by making purchases on our website or by telephone or by corresponding with us by email, telephone, post or otherwise. This includes personal data you provide when you:

• become a Software Partner or Business Customer of ours;
• subscribe or request marketing to be sent to you;
• give us feedback or contact us.

• Software Applications

We through the provision of our software applications to customers take steps to anonymise data regarding websites/videos/images which have been viewed, submitted or searched for. However, there will be occasions where we are provided with or can access personal data regarding you that has not been anonymised. This Privacy Notice provides you with transparency around the nature of this personal data which may be processed.

We may collect personal data through your use of our software applications (details of which are available on our website https://image-analyzer.com/) as follows:

• we use our Software Vendors to sell and/or licence our products to Business Customers (including businesses, universities and schools);
• the Business Customer deploys our software applications on their systems as a security and moderation tool;
• our software application will monitor Business Users and Childrens’ internet and systems usage for security and moderation purposes;
• our software applications will report personal data back to us regarding Business Users and Childrens’ internet and systems usage.
• through the above process, we will have access to Business Users and Childrens’ personal data.

Our software applications are hosted in cloud environments and subject to security and technological safeguards.

• Website

As you interact with our website, we will automatically collect Website Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookies Policy for further details.

• General Public

We may collect photos/images of the general public (available publicly on the internet) where those photos/images have been highlighted by our software applications and uploaded to our moderation platform for security and threat verification. We will not be provided with photos/images of the general public which are on private secure areas of the internet.

• HOW WE USE YOUR PERSONAL DATA
  • We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Performance of a Contract - where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate Interest - where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Comply with a legal obligation where we need to comply with a legal obligation.
  • Please click here Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
  • Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
  • We will require our Software Vendors to ensure this Privacy Notice is highlighted and made available to Business Users.
• PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
  • We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
  • We have provide separate tables for our:
• Business Customers, Software Vendors and Website Visitors;
• Business Users and Children; and
• General Public

to reflect the different ways the above types of people will interact with us and use our products and services.

• Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the tables below.

Business Customers, Software Vendors and Website Visitors
Purpose/Activity	Types of People	Type of data	Lawful basis for processing
Register - you as a new Business Customer or Software Partner	(a) Business Customer (c) Software Partner	(a) Identity (excluding photo/image) (b) Contact	Performance of a contract with you
Orders - process and deliver your order including (payment and charges)	(a) Business Customer (c) Software Partner	(a) Identity (excluding photo/image) (b) Contact (c) Transaction (e) Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
Relationship Management – to manage our relationship with you (e.g. updates to privacy policy and surveys)	(a) Business Customer (c) Software Partner	(a) Identity (excluding photo/image) (b) Contact (e) Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Administration - administer and protect our business and our website (e.g. troubleshooting, system maintenance)	(a) Business Customer (c) Software Partner (e) Website Visitors	(a) Identity (excluding photo/image) (b) Contact (d) Website Data	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
Data analytics - to improve our website, products/services, marketing, customer relationships and experiences	(a) Business Customer (c) Software Partner (e) Website Visitors	(d) Website Data	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Marketing - Suggestions and recommendations to you about goods or services that may be of interest to you	(a) Business Customer (c) Software Partner (e) Website Visitors	(a) Identity (excluding photo/image) (b) Contact (d) Website Data (e) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business) Consent where the Website Visitor is an individual consumer.

 

Business Users and Children
Purpose/Activity	Types of People	Type of data	Lawful basis for processing including basis of legitimate interest
Software Applications – provision of our software applications to Business Customers	(a) Business Users (b) Children	(f) Usage Data (g) Output & Error Data	Necessary for our legitimate interests (to fulfil our software licence/contract with the relevant Business Customer)
Software Development – collection of image/videos and logs to aid the improvement of our software applications regarding security and monitoring	(a) Business Users (b) Children	(f) Usage Data (g) Output & Error Data	Necessary for our legitimate interests (to improve our software applications for our customers)
Software Monitoring & Reporting – collection of personal data to provide security/monitoring services and reporting information to Business Customers	(a) Business Users (b) Children	(f) Usage Data (g) Output & Error Data	Necessary for our legitimate interests (to improve our software applications for our customers)
Reporting - reporting criminal activity to the relevant authorities	(a) Business Users (b) Children	(f) Usage Data (g) Output & Error Data	Necessary to comply with a legal obligation

 

General Public
Purpose/Activity	Types of People	Type of data	Lawful basis for processing including basis of legitimate interest
Software Applications – provision of our software applications to Business Customers	General Public	(a) Identity Data (relating to photo/image)	Necessary for our legitimate interests (to fulfil our software licence/contract with the relevant Business Customer)
Software Monitoring & Reporting – collection of personal data to provide security/monitoring services and reporting information to Business Customers	General Public	(a) Identity Data (relating to photo/image)	Necessary for our legitimate interests (to improve our software applications for our customers)
Reporting - reporting criminal activity to the relevant authorities	General Public	(a) Identity Data (relating to photo/image)	Necessary to comply with a legal obligation

• MARKETING

Marketing

• We strive to provide Business Customers, Software Vendors and Website Visitors with choices regarding certain personal data uses, particularly around marketing and advertising.
• We will not market to Business Users or Children.

Promotional offers from us

• We may use your Identity Data, Contact Data, Transaction Data and Website Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
• You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

• We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. This does not apply to our use of marketing organisations operating directly on our behalf.

Opting out

• You can ask us or third parties to stop sending you marketing messages at any time by:

• following the opt-out links on any marketing message sent to you;
• contacting us at any time via email; or
• logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences.
  • Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
• CHILDREN
  • We do not collect any personal data which identifies children (e.g. name, sex, race).
  • We do, however, collect personal data which relates to children’s use of the internet as part of the deployment of our software applications used by schools and other educational institutions to keep their systems secure and monitor the websites viewed, submitted and searched for.
  • A description of our processing of personal data regarding children is set out at the table “Business Users and Children” at section 3 above.
• INTERNATIONAL
  • We are based in England and comply with UK and European data protection law.
  • We work with Software Vendors who sell our software applications to Business Customers based all around the globe which involve our software application being used to monitor web usage and keep secure the browsing activities of Business Users and Children across the world.
  • Software Vendors may sell our software applications to Business Customers based outside of the UK and Europe where different data protection laws apply. We will work with our Software Vendors to ensure our processing of personal data regarding Business Customers, Business Users and Children is undertaken in accordance with those different data protection laws.
• CHANGE OF PURPOSE
  • We 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
  • If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
  • Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
• DISCLOSURES OF YOUR PERSONAL DATA

Disclosure of your personal data

• We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data”

• External Third Parties.
• Company Transactions.

External Third Parties

• We may share your personal data with the following external third parties:

• Software Vendors – we share your personal information with our software vendors who sell and/or licence our software applications to third parties who use our software applications (e.g. companies, colleges and schools)
• Service providers - who provide us with IT and system administration services.
• Professional advisers - including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities - who require reporting of processing activities in certain circumstances.

Company Transactions

We may share your personal data with businesses and other third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Disclosure requirements for third parties

• We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

• WEBSITE INFORMATION

Cookies

• We do not deploy or use cookies through any of our software applications.
• We do, however, deploy certain cookies on our website. Please see our Cookies Policy regarding the use of cookies on our website.
• You can set your browser to refuse all or some browser cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Third Party Links

• This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

• INTERNATIONAL TRANSFERS
  • Our office headquarters are based in England but use data centres located in the USA.
  • Some countries or organisations outside of the UK which we may transfer your information to will have an "adequacy decision" in place, meaning the UK considers them to have an adequate data protection regime in place. These are set out on the Information Commissioner’s website - adequacy decisions.
  • Where we transfer data to countries or organisations outside of the UK and the EEA which are not considered to have an adequate data protection regime in place, we will ensure that appropriate safeguards. For example, ensuring UK government approved standard international data transfer clauses are put in place where required.
  • Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
• DATA SECURITY
  • We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
  • We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
• DATA RETENTION
  • We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
  • To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
  • In some circumstances you can ask us to delete your data. Please see “Your Rights” section below for further information.
  • In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
• YOUR RIGHTS

Your Rights

• Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from the Information Commissioner's Office (ICO). Under certain circumstances, by law you have the right to:

• Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.
• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO).
  • If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us.

No fee usually required

• You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

• We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

• We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

• CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
  • We keep our privacy policy under regular review. This version was last updated in July 2024. Historic versions can be obtained by contacting us.
  • It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
• GLOSSARY

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Version 1.0 (July 2024)