“Personal data” of “Personal Information” is defined in Article 4(1) of the GDPR:
“‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
1. Collecting and Using Personal Information
As a User, EDM GP may collect, store and use the following kinds of Personal Information:
(a) Information about your use of our website and services (“usage information”). The usage information may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage information is our analytics tracking system. This usage information may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
(b) Information about your account (“account information”). The account information may include your name and email address. The account information may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
(c) Information included in your personal profile on our website (“profile information”). The profile data may include your The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely [the proper administration of our website and business.
(d) Personal Information that are provided in the course of the use of our services (“service information”). The service information may include timing, frequency and pattern of service use. The service information may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
(e) Information that you post for publication on our website or through our services (“publication information”). The publication information may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
(f) Information contained in any inquiry you submit to us regarding goods and/or services (“inquiry information”). The inquiry information may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
(g) Information relating to our customer relationships, including customer contact information (“customer relationship information”). The customer relationship information may include your name, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship information is you or your employer. The customer relationship information may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
(h) Information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction information”). The transaction information may include your contact details, your card details and the transaction details. The transaction information may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
(i) Information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification information”). The notification information may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
(j) Information contained in or relating to any communication that you send to us (“correspondence information”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
2. Disclosing personal information
We may disclose your personal information to the following:
(a) Any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
(b) Insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
(c) Suppliers or subcontractors insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
(d) Payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at PAYPAL.
In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3. International Data Transfers
We and our other group companies have offices and facilities in the United States of America. The European Commission has made an “adequacy decision” with respect to [the data protection laws of each of these countries. Transfers to United States of America will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Retaining and deleting personal data
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4. Tracking Policy
We use mouse-tracking technologies. These technologies may be used in analyzing trends, administering the Website, tracking Users’ movements around the Websites and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by such companies on an individual as well as aggregated basis. Our partners may also use such technologies to deliver advertisements to you as described below. While EDM GP respects the privacy of our users, we are not able to respond to Do Not Track signals set by User’s browser at this time. This website uses Hotjar, an analytics tool to track user activity, page content, click/touch, movement, scroll, and keystroke activity (in some cases). If you are located in Europe, your IP address, keystroke activity, and personal information are never stored or shared with any third-parties. If you wish to opt-out of Hotjar, you can do so at http://www.hotjar.com/opt-out.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.