Last updated: 1 January 2021
Children and privacy: We do not solicit or target persons under 18 years of age. We do not knowingly collect any information relating to children under the age of 18. By submitting information to us you represent that you are over the age of 18 and if we discover that a child under 18 has provided us with personal information, we will promptly delete such personal information from our systems.
Applicable Laws: We value our users’ privacy, and we comply with all applicable data privacy laws of the jurisdictions in which we operate, including the General Data Protection Regulation ((EU) 2016/679); the UK’s Data Protection Act 2018; the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended, collectively the “Data Laws”. The specific law that will apply to you and your data will be determined by the location in which you live: if you live in Europe, the EU GDPR will apply, and if you live in the UK, the UK’s Data Protection Act 2018 will apply. Any reference to ‘personal data’ within this Policy, has the meaning ascribed to it by either of these applicable regulations. If you are a resident of California, USA, the California Consumer Privacy Act may be applicable as explained in this Policy.
We collect information about you directly from you, from third parties, and automatically through your use of our Services. We may combine information collected from or about you from these various sources. You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide a product or feature, you may not be able to use that product or feature. The data we collect depends on the context of your interactions with EOSDA, the choices you make, including your privacy settings, and the products and features you use.
If you’re just browsing our Site or otherwise making any use of our Services we will collect different data as you do it, some of which may be considered personal data:
Some of these activities are a bit more detailed so please read below about the specifics of some of these data types and how we collect them from you.
We automatically collect information about you through your use of our Site or Services, including, without limitation:
Please see our Cookies and Other Tracking Mechanisms section below for more information. We may combine information we collect automatically with information we collect directly from you or from third parties.
We process data, including personal data (as may be defined by Data Laws), that we collect from you for the following legitimate purposes:
We use the information we collect about you:
We use the information we collect about you to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
We use aggregate information about our users and non-personal information that we collect:
We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf. For example, we may disclose your information to third-party service providers to process payments on our behalf.
We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer to a buyer or prospective buyer of our business, our professional advisers, such as our lawyers, where it is necessary for them to advise and to any other persons if we are under a duty to disclose or share your information in order to comply with any legal obligation.
We may be required by law e.g. through potential or actual litigation, court order, public or governmental authorities, or rules and regulations within or out with your country of residence to disclose all or part of your information to third parties. We may also deem it necessary to make such a disclosure in the event of an issue of national security, law enforcement or other such similar situations as we deem necessary including, for example, allegations of alleged infringement of copyright, trade marks or other third parties’ rights by users or any criminal activity, whether formal or informal, from law enforcement or a government official.
We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.
We may share your information with our affiliates or third parties to develop and deliver targeted advertising to you of our or third party products and services, or to help us to prepare marketing reports. We may send you information about our or our affiliates’ products and services, news and offers, and selected third party products and services that we think may be of interest to you. We may do this by contacting you through your email address or mobile phone number that you have provided. Any communication received from us, as consented to by you, will clearly state that it is being sent by us. You have the option to opt-out of our marketing communications at any time (see below).
If you have consented to receive marketing communications from third parties your data may be passed on to such third parties as we enter into data sharing agreements with, from time to time, for marketing and analytical reporting purposes. We cannot be held liable for the content of the third party’s communications or products/services they are promoting. If you have provided this consent, but change your mind, you can opt-out at any time (see below). Please be advised that you will also require to contact the individual third parties who have been marketing to you if you wish to stop receiving their communications directly.
If you change your mind about the marketing consent you have granted to us, you can follow the opt out procedures contained in any marketing email, or you can opt out by emailing us at firstname.lastname@example.org
Please be aware that it may take up to ten (10) business days for us to process opt-out requests. Opting out of marketing emails will not impact upon email communications you may continue to receive which are relevant to the administration of your account, or relative to any other Services you have requested to receive from us (unless those have been opted out of also).
They enable us:
We use this cookie information to help improve the services we provide to you. When you visit the publicly available sections of the Services, a session ID cookie is placed on your computer that only lasts while you’re visiting. We also place persistent cookies (also known as local storage devices) on user computers, so that we remember them to make your login in process faster and easier.
You can also block cookies by changing your browser settings so that cookies from this Site cannot be placed on your computer or mobile device. In order to do this follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” facility). Disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser.
Further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.aboutcookies.org and www.youronlinechoices.eu.
This table shows fully the cookie functions and why they are used, although our uses may change over time and it is important that you revisit this page to understand these uses:
We also use the information collected by Hotjar. If you have Cookies disabled, you won’t be tracked by any website using Hotjar. Most web browsers allow some control of most cookies through the browser settings. To find out what cookies have been set and how to manage and delete them, we recommend visiting All About Cookies (https://www.allaboutcookies.org/). You can opt-out of Hotjar here: https://help.hotjar.com/hc/en-us/articles/115011789248-Hotjar-Cookies
Our Services do not respond to Do Not Track signals. For more information about Do Not Track signals, please click here. You may, however, disable certain tracking as discussed in the Cookies and Other Tracking Mechanisms section above (e.g., by disabling cookies).
Irrespective of the above, EOSDA may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce EOSDA user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services and international law enforcement or matters of dispute.
If your account is ever terminated by us, or you have been identified by us as a potential or otherwise threat to our business, our Services, our Site or our users, your email address will be retained on our internal blacklist for as long as we deem necessary to protect the business and its users.
International Data Laws give users a number of rights which you are free to exercise at any time regarding any personal data that you have provided to us. Some of these are rights required by law, if you reside in UK or EU states, for example, however, others are applicable to all users as we wish to ensure that you have open access to your data, and the ability to amend your consents easily. You can view, edit, or delete your personal data online for many EOSDA products. You can make choices about EOSDA’s collection and use of your data. How you can access or control your personal data will depend on which products you use. You can always contact EOSDA by email@example.com. We will respond to requests to access or delete your personal data promptly and in any case within any time limits set by applicable Data Laws.
You can request a copy of the personal data that we hold about you and we aim to respond within 14 to 30 days. To obtain a copy of your data, simply email our data protection team at firstname.lastname@example.org. We may request you to provide additional information in order to verify your identity to protect the disclosure of information. We need to make sure you are who you claim to be when requesting copies of data, and once we are satisfied about your identity we will email or post a copy of your data to you. If this verification stage involves you providing us with any identification documents, these documents will be viewed for the purpose of verifying your identity prior to us making any personal data disclosures to you, and will the identification documents will not be stored for any period of time longer than this, nor will they be used for any purpose whatsoever other than facilitating your request for access. If you are not a resident of the UK or EU, we reserve the right to charge a small administration fee for provision of this information, if so permitted by the data laws governing your place of residence.
We want to make sure we have everything right in our database so please simply contact us at to make any amendments to our records by emailing email@example.com
It’s ok to change your mind about what personal data you are allowing us to use and keep and what you don’t want us to use or keep. You can contact firstname.lastname@example.org. We have to advise you however, that opting out of some personal data processing/storage will result in a loss of functionality of the services and a reduced user experience.
You have the right to have all of your personal data erased when you stop using the services. Sometimes we need to keep a record of some data for security purposes (for example to assist law enforcement agencies with any criminal investigations) or for payment processing (to prove to banks that we were authorised to take payments from you if you pay to use the services). To request erasure of all of your personal data please contact email@example.com
We may be required to act in compliance with the California Consumer Privacy Act (CCPA) and this section applies to you as an individual if you are a resident of California, USA, with references to personal information having the meaning given in that Act.
We collect the following categories of Personal Information, as defined by the CCPA:
Inferences, Identifiers, Commercial Information, Employment Information, all of which is described at Section 2 of this Policy. This information is collected for the purposes described in Sections 3 and 5 of this Policy and shared as described in Sections 4 and 5.
If you reside in California, then under the CCPA you have the following rights:
In using your information for legitimate purposes, we may combine data we collect to give you a more personalized experience. However, to enhance privacy, we have built in technological and procedural safeguards designed to prevent certain data combinations. For example, we store data we collect from you when you are unauthenticated (not signed in) separately from any account information that directly identifies you, such as your name, email address or phone number. Where any information is required to be disclosed to third party service providers to ensure the provision of Services to you, all such third parties are subject to strict data processing agreements.
You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
SOME STATES OR JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES, SO THE FOLLOWING LIMITATION AND EXCLUSIONS MAY NOT APPLY TO YOU. TO THE FULLEST EXTENT ALLOWED BY APPLICABLE LAW, UNDER NO CIRCUMSTANCES AND UNDER NO LEGAL THEORY (INCLUDING, WITHOUT LIMITATION, TORT, CONTRACT, STRICT LIABILITY, OR OTHERWISE) SHALL EOSDA (OR ITS LICENSOR(S) OR SUPPLIER(S)) BE LIABLE TO YOU OR TO ANY OTHER PERSON FOR (A) ANY INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES OF ANY KIND, INCLUDING DAMAGES FOR LOST PROFITS, LOSS OF GOODWILL, WORK STOPPAGE, ACCURACY OF RESULTS, OR COMPUTER FAILURE OR MALFUNCTION, OR (B) ANY AMOUNT, IN THE AGGREGATE, IN EXCESS OF THE GREATER OF (I) $100 OR (II) THE AMOUNTS PAID BY YOU TO EOSDA IN CONNECTION WITH THE SERVICES IN THE THREE (3) MONTH PERIOD PRECEDING THIS APPLICABLE CLAIM, OR (C) ANY MATTER BEYOND OUR REASONABLE CONTROL.
In accordance with the applicable UK and EU Data Laws, the following representatives are authorised to receive written communications on our behalf from the relevant supervising authorities and any data subjects exercising their rights under the UK Data Protection Act 2018, or the European General Data Protection Regulation:
UK Representative (in accordance with the UK Data Protection Act 2018):
Elpha Fox Privacy, 7 Bell Yard, London, WC2A 2JR
We hope that we will be able to directly resolve any complaint that you may have, however, if you are not happy with how we handle any complaint, depending on your place of residence, you may be able to raise a complaint at any time to your country’s national data protection authority.