Edisen Privacy Policy

Edisen Limited (“Edisen”, “us”, “we”, or “our”) operates the edisen.com website, as well as provides products and services within our portfolio – overall, these are related to as the “Service”.

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service, and the choices you have associated with that data. We are the controller and responsible for your personal data.

We use your data to provide and improve our Service. By using our Service, you agree to the collection and use of information in accordance with this policy. It is important that you read this policy so that you are fully aware of how and why we are using your personal data.

1 DEFINITIONS

• Service: Service means the website operated by Edisen, as well as the business service and product offerings.
• Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
• Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Cookies: Cookies are small pieces of data stored on your device (computer or mobile device).
• Data Controller: Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
• Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
• Data Subject (or User): Data Subject is any living individual who is using our Service and is the subject of Personal Data.

2 INFORMATION COLLECTION AND USE

• We collect, use, store and transfer several different types of information for various purposes to provide and improve our Service to you. This may be collected:
  • When you directly interact with us (for example, when you fill in a form or correspond with us by email, create an account, require marketing to be sent to you or subscribe to our Services)
  • When you interact with our website (for example we automatically collect technical data about your browsing actions and pattens using cookies and similar technologies. Please see our cookies policy for further details.
  • From third parties such as analytics providers (such as google and facebook).

2.1 INFORMATION COLLECTION AND USE

• While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify. Identity data may include, but is not limited to:
  • Email address
  • First name and last name
  • Company
• Contact data may include but is not limited to:
  • Phone number
  • Company
  • Address, State, Province, Postal code, City
•  
• 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.
• We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

2.2 USAGE DATA

• We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device or such (“Usage Data”).
• This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
• When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

2.3 LOCATION DATA

• We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.
• You can enable or disable location services when you use our Service at any time, through your device settings.

2.4 TRACKING COOKIES DATA

• We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
• Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
• You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

• Examples of Cookies we use:
  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

3 LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

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:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• 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.
• Where we need to comply with a legal obligation.

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.

4 USE OF DATA

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Usage, Location and Cookies and Tracking 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 Services from us and you have not opted out of receiving that marketing.

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.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 or other transactions.

5 RETENTION OF DATA

Edisen will retain your Personal Data only for as long as is reasonably necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to satisfy any legal, regulatory, tax, accounting or reporting requirements), if we reasonably believe there is a prospect of litigation in respect to our relationship with you and to enforce our legal agreements and policies.

Edisen will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

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.

6 TRANSFER OF DATA

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Please note that our servers are based in the EU and therefore our processing of your Personal Data will involve a transfer of Personal Data outside the UK. Edisen will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

7 TRANSFER OF DATA

We may share your Personal Data with third parties and for the purposes set out below. 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.

7.1 BUSINESS TRANSACTION

• If Edisen is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. 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.

7.2 Internal Third Parties

• Other companies in the Edisen Group and who are based in the UK and EEA and provide IT and system administration services and undertake leadership reporting.

7.3 External Third Parties

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and EEA who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Please also see details of our external Service Providers set out in Section 11.

Edisen does not sell or forward your personal data to third party companies, which they can then further use for target Marketing purposes.

8 SECURITY OF DATA

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. 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..

9 "DO NOT TRACK" SIGNALS

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

10 YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the UK or European Economic Area (EEA), you have certain data protection rights. Edisen aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:

• The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Edisen relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.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 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. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. The measures that Edisen takes to ensure a person’s data privacy rights are respected also comply with the California Consumer Privacy Act (CCPA).

11 SERVICE PROVIDERS

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Before engaging a third party to collaborate on a specific engagement, we ensure they are compliant with the latest data privacy policies, and we will also obtain permission from our client(s), if required.
On our website we may use third-party Service Providers to monitor and analyze the use of our Service.

11.1 Google Analytics

• Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network
• For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

11.2 Albacross

• We use Albacross for tracking visitors related to companies that we could become potential partners with. Albacross uses the data collected to track and monitor the use of our Service for the purpose of lead generation.
• For more information on the privacy practices of Albacross, please visit the Albacross Privacy Terms web page: https://albacross.com/privacy-policy/

12 LINKS TO OTHER SITES

Our Service may contain links to other sites, plug-ins and applications that are not operated by us. 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. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

13 CHILDREN’S PRIVACY

Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

14 CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

15 CONTACT US

If you have any questions about this Privacy Policy or our privacy practices, please contact us:

• by e-mail: info@edisen.com