We are committed to protecting and respecting your privacy. This policy (together with the relevant terms of use and commercial terms for our EBS software (each a Product, and collectively, Products and any other documents referred to in each) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the applicable data protection legislation, we, Emvenci Limited (company no. 08672175) of Kemp House, 152-160 City Road, London, England, EC1V 2NX, are the data controller.

PERSONAL DATA WE MAY COLLECT FROM YOU

We may collect and process the following personal data about you:

Personal Data you give us. You may give be required to provide us with personal data about you when using our Products or by corresponding with us by phone, e-mail or otherwise. This includes personal data you provide when you register to use a Product, subscribe to any of our services, and when you report a problem with a Product(s). The personal data you give us may include items such as your name, address, e-mail address, phone number, employer and job role. We rely on ‘contractual necessity’ as the lawful ground for the processing of your personal in such cases.

Personal Data we collect about you. Regarding the processing of some specific items of personal data that assist us to improve our Products and to provide our services, we rely on ‘legitimate interests’ as the lawful ground for such processing. This includes automatically collecting and using the following personal data: technical information, including the type of computer or device you use to use the Product, a unique device identifier, mobile network information, your operating system, the internet protocol address used to connect your computer or device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and information about your session, including the full uniform resource locators clickstream to, through and from our Product(s) (including date and time), response times, errors, interaction information (such as scrolling, clicks, and mouse-overs), and any phone number used to call our customer service number.

USES MADE OF THE PERSONAL DATA

Personal Data you give to us. We will use this personal data:

• to carry out our obligations arising from any contracts entered between you and us and to provide you with the information, products and services that you request from us;
• to provide you with information about other goods and services we offer that are like those that you have already purchased or enquired about;
• to notify you about changes to our service; or
• to ensure that content from our Product is presented in the most effective manner for you and for your computer.

Personal Data we collect about you. We will use this personal data:

• to administer our Product and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our Products and to ensure that content is presented in the most effective manner for you and for your computer or device;
• to allow you to participate in interactive features of our Products and services, when you choose to do so;
• as part of our efforts to keep our Products safe and secure;
• make suggestions and recommendations to you and other users of our Products about goods or services that may interest you or them.

DISCLOSURE OF YOUR PERSONAL DATA

We may share your personal data with any member of the group of companies of which we are a part. We may disclose your personal data to third parties:

• 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;
• if Emvenci Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets; or
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; in order to enforce or apply our relevant terms of use relating to each Product and other agreements; or to protect the rights, property, or safety of Emvenci Limited, our users, or others. This includes exchanging personal data with other companies and organisations for the purposes of fraud protection and credit risk reduction.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you, or that you provide to us, may be stored by us at a destination anywhere within the European Economic Area (EEA). Transfer of your personal data outside the European Economic Area is subject to your prior written approval in each case. If you approve of the transfer and the processing is not taking place in a destination or by an international organisation where the European Commission has decided that the destination or one or more specified sectors or frameworks ensure an adequate level of protection, we shall enter into a binding agreement with you based upon European Union model clauses.

RETENTION OF YOUR PERSONAL DATA

We will retain your personal data for as long as your account is active or as needed to provide you with access to our Products and services. If you wish to cancel your account or request that we no longer use your personal data to provide you with access to our Products, contact us at [email protected]. We will only retain and use your personal data thereafter as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

SECURITY OF YOUR PERSONAL DATA

The security of your personal data is important to us. We comply with accepted industry standards to protect the personal data submitted to us. We use strict procedures and advanced security features to try to prevent unauthorised access. No method of transmission over the Internet, or method of electronic storage, is however 100% secure. Therefore, we cannot guarantee its absolute security.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of a Product, you are responsible for keeping this password confidential. You are not permitted to share a password with anyone.

Our Product(s) may, from time to time, contain links to and from the websites of our partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. We encourage you to carefully read the privacy notice of any website you visit.

YOUR RIGHTS

You have the following rights in relation to the handling of your personal data:

• You have the right to access personal data held about you;
• You have the right to have inaccuracies corrected for personal data held about you;
• You have the right to have personal data held about you erased;
• You have the right to object to direct marketing being conducted based upon personal data held about you;
• You have the right to restrict the processing for personal data held about you, including automated decision-making;
• You have the right to data portability for personal data held about you;

You can exercise any of your rights outlined above by contacting us at [email protected]. Within one month of receiving a request made under these rights, we will action the request. Where we receive a large number of requests, or receive especially complex requests, this may be extended by a maximum of two further months. If we fail to meet these deadlines or if you feel your rights have not been adequately respected, you may complain to the Supervisory Authority and/or seek a judicial remedy.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on our web site and, where appropriate, notified to you by e-mail.

CONTACT

Questions, comments and requests regarding this privacy policy or any privacy topic are welcomed and should be addressed to [email protected].