Privacy and Cookies Policy
Effective Date: 16/01/2022
- Who are we?
- We are Eurointelligence Limited, a company incorporated in England and Wales under company number 5778200, trading as “Eurointelligence”. Our registered office is at Oxford Centre for Innovation, New Road, Oxford, Oxfordshire, OX1 1BY, United Kingdom.
- What’s the point of this policy?
- It tells you what to expect when we collect your personal data. Please only use our website and services if you are completely happy with this policy.
- To make sure you have a full picture of how we collect and use your personal data, this policy describes:
- who is responsible for the personal data that we collect about you;
- the personal data we collect about you;
- how we will use it;
- who we may disclose it to; and
- your rights and choices in relation to your personal data.
- Generally, this policy covers only information provided to us. If you give personal data to other people, such as by visiting any websites linked to from our website or choosing to pay for your subscription for our services using a third payment service (we currently use PayPal, Stripe and China UnionPay) those third parties will separately process your personal data in order for you to use their service. Data shared with third parties will be processed in accordance with their privacy policies and we recommend you review the information in those notices before you share any personal data or use their payment service.
- Might the policy change?
- Yes. Please check whenever you visit our website. We will assume you agree to the new version of the policy if you use the website after its effective date. We will generally notify you or otherwise draw your attention to any material changes.
- Who is responsible for the personal data that we collect?
- We are the data controller for the purpose of data protection law, in respect of your personal data collected and used through your use of the website and our services. This is because we determine the purpose for which your personal data is used and how we use your personal data.
- What do we collect?
- Information which you or the entity subscribing to our services provides to us in order for you and the entity to receive the benefit of our services, such as your name, email address, postal address and telephone number, as well as any other information provided to us by email or by completing the form to contact us on our website.
- Automated information such as the internet protocol (IP) address used to connect your device to the internet and access our website, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, the website from which you arrived at our service, details of your activity with date/time stamps including pages you visited and your searches/transactions.
- We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
- What’s our reason/legal basis for collecting the information?
- We use and retain this information:
- where you subscribe to our services, as it is necessary to enter into or perform the contract we have with you (or to take steps at your request prior to entering into that contract);
- where you benefit from our services due to your connection with an entity subscribing to our services, as it is in our legitimate interests to process your personal data in order to provide our services; and
- where you use our website or contact us by email or through the form on our website, and the retention does not fall within (a) above, as it is in our legitimate interests to process your personal data to allow us to reply to you and to help us to provide you with a good experience when you browse our website and make improvements to improve our services.
- We may also use your data where we are subject to a legal obligation or in order to take legal action to enforce the terms of any contract entered into with you or contractual notices to which you are subject.
- If we are entitled to send you marketing materials and you have not objected to this, we may send you email marketing from time to time. For business customers, it is within our legitimate interests to send you marketing communications. If you are an individual, we rely on soft opt-in consent. You will have the opportunity to opt-out of use of your data for marketing purposes when we first collect your data and via an unsubscribe function within each communication.
- We use and retain this information:
- What about cookies?
- Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Session cookies are temporary cookies that remain in the cookie file of your browser only until your browser is closed. They allow websites to link your actions during a browser session. Persistent cookies stay in the cookie file of your browser for longer (how long will depend on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them and how to delete cookies already stored on your device, visit: www.allaboutcookies.org.
- The following kinds of cookies may be used on this website:
- Session cookies: These are essential for our service and enable us to keep track of your movement from page to page and store your selections so you do not get asked repeatedly for the same information. They allow you to proceed through many pages of the website quickly and easily without having to authenticate or reprocess each new area you visit. These cookies are kept for the duration of your browsing session.
- Google cookies: Persistent cookies (cookies remaining on a device beyond a browsing session) are set in connection with the following Google services on our website and these cookies may involve certain information (such as your IP address and web address of the page you’re visiting) being sent to Google:
- Simplecast for podcasts: Our website includes Simplecast.com cookies third party persistent cookies (up to two years) set by Simplecast in connection with the podcast player on our website. These cookies registers a unique ID that is used to generate statistical data on how the visitor uses the webplayer and help to identify if the user is in an active session on a site or if this is a new session for a user (i.e. cookie doesn’t exist or has expired). You can find more information here. These cookies are kept for up to 2 years.
- Cookie-warning cookie: This cookie takes note of whether you are happy to accept cookies on this website based on your response to the message which appeared when you first visited the website. This cookie is kept for up to one year.
- What do we do with personal data?
- Provide our services, e.g. send service messages, process payments, fulfil orders.
- Use it to recognise you when you visit or return to our service, when you log into any secure area of our website, to track anonymised traffic and usage patterns, prevent or detect fraud or abuses and help us improve our service.
- How long do we keep it?
- Where you subscribe to our service or receive the service to your email address due to your connection with a subscribing entity, we will generally keep your information for up to six years after your account is closed for tax reasons and/or to help deal with any disputes. We retain your information received for other purposes for [INSERT] years. These timeframe may vary if we are legally required to keep information for a particular period.
- To whom do we send or make available your personal data?
- To other people who supply us with a service and who process data on our behalf e.g. e-commerce platform providers, database services, website hosts, content delivery networks and businesses which help us send communications or monitor our website. We require them 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
- To the police or other relevant authorities or to complainants, if we think the personal data breaches our terms and conditions, or it is necessary to protect us or others, or that a criminal offence may have been committed, or where required by law or where requested by the police or other appropriate authorities.
- To third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or instructions of a regulatory body (including in connection with a court order).
- To other third parties in order to enforce or apply the terms of any agreements we have with or otherwise concerning you (including agreements between you and us) or to protect our rights, property or safety of our customers, employees or other third parties.
- To our professional advisors (including accountants, lawyers and auditors) that assist us in carrying out our business activities.
- To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.
- What happens to your payment details?
- These go direct to our payment partners. We do not receive such information except as stated above. To ensure your details are not being used without consent, our payment partners may send your personal data to relevant third parties including credit reference and fraud prevention agencies, who may keep a record of that information.
- Do we send your information outside the European Union?
- Your personal data which we collect is stored within the UK and EU and is not transferred to any third countries except for the following:
- Your personal data may be transferred to the US by the following companies as we have agreements in place providing certain safeguards for your personal data: Google (analytics), Amazon (mailbox hosting).
- What rights do you have?
- You have certain rights with respect to your personal information. The rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights. You can exercise these rights by emailing us at firstname.lastname@example.org.
Summary of your rights
Right of access to your personal information
You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions.
Right to rectify your personal information
You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.
Right to erasure of your personal information
You have the right to ask that your personal information be deleted in certain circumstances. For example:
Right to restrict the use of your personal information
You have the right to suspend our use of your personal information in certain circumstances. For example:
Right to data portability
You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible.
The right only applies:
Right to object to the use of your personal information
You have the right to object to the use of your personal information in certain circumstances and subject to certain exemptions. For example:
Right to withdraw consent
You have the right to withdraw your consent at any time where we rely on consent to use your personal information.
Right to complain to the relevant data protection authority
You have the right to complain to the relevant data protection authority, which is the Information Commissioner's Office, where you think we have not used your personal information in accordance with data protection law.
You can contact them on 0303 123 1113, go online to www.ico.org.uk/concerns. or write to them at:
Information Commissioner's Office
13.2 For more information about your rights, visit the ICO’s website: www.ico.org.uk.