Imperative Privacy Policy

1. Data Controller

The data controller of personal data collected through the Imperative website and related services is:

AXA ICAS Limited (referred to as “AXA ICAS” in this Policy).
Registered in England & Wales under company number 0254857
Registered office: 5 Old Broad Street, London EC2N 1AD

At AXA ICAS, we are committed to protecting your personal data and complying with the Data Protection Act 1998 and associated legislation. This Privacy Policy outlines the type of information that is collected by us on this website, and how we use and protect it. This Policy also outlines your rights regarding data protection, and tells you how to contact us. This Policy applies only to this website. It does not apply to banners, advertisements or promotions we may sponsor or participate in on websites owned by third parties.

2. Personal data and its uses

(a) What we collect and why

When referring to “personal data”, we mean information we collect from you, from which you may be personally identified. Typically, this may include your name, address, telephone number (including mobile number), credit card information, screen name, email address, age, sex and family status, but may also include other information such as habits, preferences and lifestyle. If you subscribe for the AXA ICAS services offered via the website we may also collect sensitive personal from you such as your health profile, weight, activity etc for the purposes set out below.

Please be assured that we will not collect any personal data from your visits to our site unless you provide this information voluntarily.

We will not share any personal data collected from you with your employer.

When you supply personal data to us through this website, it will be clear what we plan to use the data for and we will seek your consent to such use. We will then use it only for such purposes. Typical purposes are as follows:

(i) Providing the AXA ICAS services

If you subscribe to the AXA ICAS services, we may collect data about your physical condition and general wellbeing, for the purposes of providing you lifestyle and coaching advice. We also provide a capability for those helping you with your lifestyle change (e.g. personal trainer or healthcare professional) to view your progress with your express permission. You can withdraw this permission at any time.

(ii) Answering your queries

Where you send us personal data in the context of asking us a question or query (for example, about the company, or its products or services or their quality or availability), we shall use the data you provide in order to respond to your question. In some cases, it may be necessary to share your details with other third party data processors.

(iii) Entering a promotion

We may use personal data submitted in an entry form for a promotion for the purpose of administering the promotion in accordance with its stated rules. Such rules may require the publication of abbreviated winners’ identity details, and may require winners to participate in future publicity. The promotion may be administered by third party agencies on our behalf, which may have access to the data you submit (see data processors).

(iv) Fulfilling a contract or order

We may use personal data you submit to us when ordering goods or services from us for the purpose of fulfilling that order, and it may be necessary for us to share such data with third parties such as the card payment services provider or carrier of goods.

(v) Future direct marketing

If you opt-in to receive marketing from us we may from time to time send you information or offers about our goods and services which we believe may be of interest to you. However, you may unsubscribe from or opt out of such future contact at any time by contacting us with such a request at Imperative.Support@axa-icas.com.

(b) Processing outside the EEA

This website is hosted in the United Kingdom by a professional hosting company, currently DataPipe Inc, which is compliant with the Data Protection Act 1998 and associated legislation including the Information Security Management Systems standard ISO27002. DataPipe Inc provides an offsite backup service and stores our database backups at their data centre in the United States. The United States currently has no federal law protecting personal data, but the hosting organisation is a signatory of the Safe Harbor Framework which provides industry-standard protection for your personal data. All collection, storage and processing of your data shall be in accordance with the Safe Harbor Framework.

3. Data Processors

At times we may retain third parties to process or analyse data we collect on our websites, including your personal data. For example, the website may be maintained or hosted by a specialist IT services agency and any promotions may be administered by a sales promotion agency. In addition, if you order a product or service from us, we may share personal data with suppliers and other third parties to allow payment and delivery of such product or service. These suppliers and other third parties are contractually obliged not to use your personal data in any way other than that which we have specified.

4. Security

We take reasonable precautions to keep your personal data secure, and require third party data processors to do likewise. All personally identifiable information is subject to restricted access to prevent unauthorised access, modification or misuse. Please note, however, that we will release your personal data if required to do so by law, or by search warrant, subpoena or court order.

5. Cookies

(a) Use of cookies

A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that the website can recognise who you are. A cookie will typically contain the name of the domain from which the cookie has come, the "lifetime" of the cookie, and a value, usually a randomly generated unique number.

When you visit our website we send you a cookie. Cookies may be used in the following ways:

to help us recognise you as a unique visitor when you return to our website and to allow us to tailor content or advertisements to match your preferred interests or to avoid showing you the same adverts repeatedly; and

to compile anonymous, aggregated statistics that allow us to understand how users use our website and to help us improve its structure. We cannot identify you personally in this way.

Two types of cookies may be used on this website; "session cookies", which are temporary cookies that remain in the cookie file of your browser until you leave the site, and "persistent cookies", which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie). You can choose to disable these cookies by following the process set out in Section 5(d) below.

(b) Use of web beacons

Some of our website pages may contain electronic images known as “web beacons” (sometimes known as “clear gifs”) that allow us to count users who have visited these pages. Web beacons collect only limited information which including a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These web beacons do not carry any personally identifiable information and are only used to track the effectiveness of a particular campaign. Because web beacons are the same as any other content request included in the recipe for a web page, you cannot opt out or refuse them. However, where they are used in conjunction with cookies they can be rendered ineffective by either opting out of cookies or by changing the cookie setting on your browser.

We may use a third party to serve advertisements on our website. Cookies may be associated with these advertisements to enable the advertiser to track anonymously the number of users responding to the campaign. We do not have access to or control of cookies placed by third parties.

(d) Disabling/enabling cookies

You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our site if cookies are disabled.

There is a number of ways to manage cookies. If you use different computers in different locations you will need to ensure that each browser is adjusted to suit your cookie preferences. Some modern browsers have a feature that will analyse website privacy policies and allow a user to control their privacy needs. These are known as "P3P" features (Privacy Preferences Platform). You can easily delete any cookies that have been installed in the cookie folder of your browser. For example, if you are using Microsoft Windows Explorer:

open Windows Explorer;
click on the "Search" button on the tool bar;
type "cookie" into the search box for "Folders and Files";
select "My Computer" in the "Look In" box;
click "Search Now";
double click on the folders that are found; and
select any cookie file and delete it.

If you are not using Microsoft Windows Explorer, then you should select "cookies" in the "Help" function for information on where to find your cookie folder.

6. Your rights

Under UK data protection law, your rights include the right to

withdraw your consent to the processing of your personal data to which you have previously consented;
obtain a copy of the personal data which we hold about you (we reserve the right to charge a small fee for the exercise of this right);
object to the processing of your personal data for the purpose of direct marketing; and
have incorrect personal data we hold about you corrected.