ENCHANGE (“We”) are committed to protecting and respecting your privacy.
This policy 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.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Definitions
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data – Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Who are we?
ENCHANGE is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are:
Address: 22 London Road Horsham, West Sussex, RH12 1AY
Phone: +44 1403 275 576
For all data matters contact our office at improve@enchange.com
The purposes of processing your personal data
We use your personal data for the following purposes:
- We may use the information to improve our website and service offer.
- We may use the information to customise the website according to the interests of the visitors.
- We may periodically send promotional emails about our services, special offers or other information which we think those visitors who shared their contact details with us may find interesting, using the email address which they have provided.
- We may send email notifications regarding blog posts published on our website to subscribers.
- From time to time, we may also use this information to contact visitors for business development or market research purposes. We may contact them by email or phone.
- We may use personal information for recruitment purposes.
The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we collect and process the following categories of your data:
- When completing conversion forms and other forms on our website we may collect your name and email address, telephone number, company name and position.
- Your CV that you have sent to us in email or uploaded it to our website.
- When you contact us in email regarding our services and products we may collect your email address.
- Details of your visits to the websites including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
We have obtained your personal data via forms you have completed and submitted on our website, via email messages you sent and via web analytical and marketing automation tools such as Google Analytics and Hubspot, that use cookies to help us to analyse how users use our site.
What is our legal basis for processing your personal data?
We have a number of lawful basis for collecting and processing personal data. For general personal data obtained via the website our lawful basis is consent of the data subject. However, you always have the right to object to processing for the purposes of direct marketing, whatever lawful basis applies.
More information on lawful processing can be found on the ICO website.
Sharing your personal data
Your personal data will be treated as strictly confidential. We will never sell your data to third parties for the purpose of marketing. We will never transfer your personal data to any third parties without your permission unless indicated in this privacy policy. We may share your personal data with third parties without obtaining further consent from you including:
- Our business partners, suppliers and subcontractors for the performance of any contract we mutually agree with you.
- Where we outsource any of our business functions under which we collect or store your data, in which case we will ensure that any such service provider adheres to at least the same obligations of security regarding your data as undertaken by us.
- If we are under a duty to disclose or share your personal data in compliance with any legal obligation, or to enforce or apply our Terms & Conditions and other agreements; or to protect our rights, property, or safety of our employees, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, credit risk reduction and recovery of unpaid services.
How long do we keep your personal data?
We retain personal data that you provide to us where we have an ongoing legitimate business need to do so for example to perform the services you requested from us, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements. After such time, we will either delete or if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data. However some resources are only available on our website if you provide us with some personal data such as your email address.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, WHERE CONSENT WAS YOUR LAWFUL BASIS FOR PROCESSING THE DATA;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
Transfer of Data Abroad
We use Google Analytics and Hubspot Marketing Automation tools on our website. These tools use cookies to help us to analyse how users use our site. The information generated by the cookies about your use of our Websites (including your IP address) will be transmitted to and stored by Google and Hubspot on servers which may be located outside of the European Union. Google and Hubspot may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s and Hubspot’s behalf.
Personal data that you chose to share with us via online forms (such as your name and position, email address and phone number and your company) are processed and held by Hubspot on servers which may be located outside of the European Union. HubSpot participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework. Hubspot’s affiliated entities also adhere to the Privacy Shield principles. Further information is available on the following links:
Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
How to access and control your personal data
To exercise all relevant rights, queries or complaints please in the first instance contact our office at improve@enchange.com.
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, updating your communication preferences, or by sending us email us at improve@enchange.com or postal mail to Enchnage Ltd. 22 London Road, Horsham, West Sussex, RH12 1AY, UK, Attention: Privacy.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.