Epicenter BV (“we“, “us”, “our”) are committed to protecting and respecting your privacy.
For the purposes of EU and UK data protection laws and any applicable national implementing laws, regulations and secondary legislation relating to the processing of personal data (together “Data Protection Law”), the data controller is Epicenter BV of Printerweg 36, 3821 AD, Amersfoort, the Netherlands.
Legal Basis for Processing
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:
- To fulfil our contractual obligations to you.
- Where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- To comply with a legal obligation.
To the extent we process your personal data for any other purposes, we ask for your consent in advance or require that our partners obtain such consent.
PERSONAL DATA WE MAY COLLECT ABOUT YOU
We may collect and process personal data about you. Personal data, or personally identifiable information, means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data). We collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data: includes first name or last name,
- Contact Data: email address
- Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site or the Services.
- Usage Data: includes information about how you use our Site and Services, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site and Services (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- Marketing and Communication Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special Category Data: We do not collect, store and/or use special category data about you.
HOW PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you including via:
- Direct Interactions. You may give us your Identity Data and Contact Data when you fill in forms or correspond with us by post, phone, email or otherwise. This includes personal data you provide when you use our Site or ask to receive our newsletter, request marketing to be sent to you, attend a conference or webinar, give us feedback or contact us and when you report a problem with our Site or Services.
- Automated Technologies or Interactions. As you interact with our Services, Sites or emails, we automatically collect Technical Information about your device, browsing actions, patterns, Location Data and Usage Data. We collect this personal data by using cookies, server logs, web beacons, pixels, and similar technologies about your device, and your use of our Site. Please see the Cookie section below for further details.
PERSONAL DATA WE RECEIVE FROM OTHER SOURCES
We work closely with third parties (including, for example, business partners, sub-contractors technical service providers, advertising networks, analytics providers and search information providers) and may receive the following personal data about you from them:
- Technical Data: from analytics providers, advertising networks and search information providers.
- Identity and Contact Data: from providers of chat/communication/helpdesk services with customers including via email.
- Email Communications and Contact Data: from providers of email communications service providers.
- Business Contact Data: from CRM service providers who manage contacts and keep a record of communications/ interactions with Site users.
You can set up your browser options, to stop your computer accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use the whole of the Site.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
USES MADE OF PERSONAL DATA
We have set out below, in a 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.
Note that we may process your personal data for more than one lawful basis 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 table below.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a prospect or new customer.||(a) Identity
|Performance of a contract with you|
|To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, updates, reporting and hosting of data)||(a) Identity
|(a) 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)
(b) Necessary to comply with a legal obligation
|To deliver relevant Site content to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Site and Services, marketing, customer relationships and experiences||(a) Technical
|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)|
We will not sell or rent your personal data to anyone.
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.
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.
DISCLOSURE OF YOUR PERSONAL DATA
Personal data we share with third parties. We may share your personal data with the third parties set out in our Third Party Supplier List for the purposes set out in the table above. Below is a summary of the types of third parties used:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you to provide services such as IT and system administration services, email communications, hosting services, backup services, credit card processing, research, development, marketing and customer support.
- Analytics and search engine providers that assist us in the improvement and optimisation of our Site and Services.
- Professional advisors acting as service providers to us in relation to the Site or Services – including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Tax authorities, regulators and other authorities who require reporting of processing activities in certain circumstances.
Personal data we disclose to third parties. 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 we or a member of our group of companies or substantially all of their assets are acquired by a third party, in which case personal data held by them about their customers will be one of the transferred assets.
- Including Aggregated Data in the normal course of operating our business; for example, with other Site users, our customers or publicly to show trends or benchmark the general use of our Site.
Our Services are global and your personal data may be stored and processed in any country where we have operations, our staff are located or where we engage service providers engaged in, among other things, the provision of support services. This will involve a transfer of your personal data to countries outside of your country of residence, where data protection rules are different from those of your country of residence.
Processing of your personal data may involve a transfer of data to countries outside the European Economic Area (“EEA“), Switzerland or the UK.
Our Site is accessible via the internet and may potentially be accessed by anyone around the world. Other users may access the Site from outside the EEA, Switzerland or the UK.
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. For example all information you provide to us is stored on our secure servers. 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will endeavour to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Site or the Services. Any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
LINKS TO OTHER WEBSITES
Our Site and Services may, from time to time, contain links to and from the websites of our partner networks, 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. Please check these policies before you submit any personal data to these websites.
You have the right under Data Protection Law, free of charge, to request:
- Access to your personal data.
- Rectification or deletion of your personal data.
- A restriction on the processing of your personal data.
- Object to the processing of your personal data.
- A transfer of your personal data (data portability) in a structured, machine readable and commonly used format.
- Withdraw your consent to us processing your personal data, at any time.
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.
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.
- Marketing: We may use your Identity, Contact, Technical, Usage and Profile 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).
- Promotional Offers from us: We will send you marketing emails if you “opt in” to receive marketing emails when registering on our Site, or if you have enquired about, or purchased any of our goods or services from us and you have not opted out of receiving such marketing.
- Third Party Marketing: We will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.
- Opt out: Please note that, if you change your mind about being sent marketing emails you can “opt out” at any time by clicking the “unsubscribe” link at the bottom of any marketing email. Once you “opt out”, you will no longer receive any marketing emails from us. We will continue to communicate with you regarding your service billing and support via email.
We retain personal data for as long as reasonably necessary to fulfil the purposes for which it was provided or collected, 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, if we reasonably believe there is a prospect of litigation in respect of our relationship with you, to comply with law enforcement requests, maintain security, prevent fraud and abuse, resolve disputes, enforce our legal agreements, or fulfil your request to “unsubscribe” from further messages from us.
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.
This will be for as long as we provide access to the Site
AGE OF USERS
This Site and the Services are not intended for and shall not be used by anyone under the age of 16.
By post: Epicenter BV of Printerweg 36, 3821 AD, Amersfoort, the Netherlands.
By email: firstname.lastname@example.org
Third Party Supplier List
|Google Inc||Website analytics services||http://www.google.com/policies/privacy/|
|ActiveCampaign||Email service provider||https://www.activecampaign.com/legal/privacy-policy|
|Savvii||Hosting service provider||https://www.savvii.com/en/terms-and-conditions/|