Standard End User Access Agreement

EUAA Privacy Notice

Last updated: 1^st May 2018

ContactEngine Limited (“we”, “us”, “our”, “ours”, “ContactEngine Limited”) respects your privacy and is committed to protecting it. This notice (1) describes our practices in connection with the use of our software as a service conversation engine (“ContactEngine”) and (2) only applies to the extent we are data controller.

You may only use ContactEngine if you have been authorised by a client or partner of ours, please refer to our End User Access Agreement to determine the basis of your access to ContactEngine. The most up-to-date version of our End User Access Agreement can be found at www.contactengine.com/euaa.

Identity and contact information of the Data Controller

For the purposes of data protection legislation in the European Union, the data controllers (i.e. the person that determines the purposes and manner in which your personal data are processed) are:

our client or partner, in respect of whether you are authorised to use ContactEngine. Please contact our relevant client or partner for further information and details of their data protection practices; and
ContactEngine Limited, in respect of (i) the enforcement of our End User Access Agreement; and (ii) the use of technical data for the purposes of improving ContactEngine Limited is a company incorporated and registered in England and Wales (company number 05651154) with its registered office at Janelle House Hartham Lane, Hertford, Herts, SG14 1QN, United Kingdom.

Questions, comments and requests regarding this notice are welcome and should be addressed to support@contactengine.com.

Information we may hold about you

A breakdown of the personal data we may hold about you is set out at the end of this notice.

How personal data are collected

We may gather personal data in three main ways: (1) our client or partner provides us with your personal data; (2) you provide us with your personal data; or (3) personal data is collected automatically (such as the automatic recognition of your IP address or placement of cookies on your device).

IP Addresses

Our servers may automatically recognise users’ IP addresses (the number assigned to computers on the Internet); the activity of the user’s browser; and the time users use ContactEngine. We may also gather anonymous traffic data that does not personally identify you, but that may be helpful for improving the services we offer.

We use cookies to distinguish you from other users. This helps us provide you with a good experience when you use ContactEngine. Please see our Cookie Policy for more details. The most up-to-date version of our Cookie Policy can be found at www.contactengine.com/privacypolicy.

For more information on managing cookies, please go to www.allaboutcookies.org, which has further information about online privacy.

Where we store your personal information

Unless otherwise described in this notice, the personal data we collect from you is stored in the European Economic Area (“EEA”).

Disclosure of your information

In addition to the disclosure described at the end of this notice, we may disclose your personal data:

to a member of our group, which means our subsidiaries, our ultimate holding company, and its subsidiaries (lawful ground: processing is necessary for the legitimate interests of ContactEngine Limited (i.e. to understand who is using ContactEngine));
if we, or substantially all of our assets, are acquired by a third party (lawful ground: processing is necessary for the legitimate interests of ContactEngine Limited (i.e. to dispose of its business); or processing is necessary for compliance with a legal obligation to which we are subject);
if we cease operations. Your data may be transferred to and used by another company which offers similar or related products or services to ContactEngine Limited (lawful ground: processing is necessary for the legitimate interests of ContactEngine Limited (i.e. to protect its business as a going concern));
if we believe it appropriate in order to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, and violations of the End User Access Agreement (lawful ground: processing is necessary in order to protect the vital interests of the data subject or of another natural person; or processing is necessary for the legitimate interests of ContactEngine Limited (i.e. to ensure the protection of its business)); or
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of ContactEngine Limited our customers, or others. We shall have no duty to notify you of such compliance with the law (lawful ground: processing is necessary for compliance with a legal obligation to which we are subject).

Your rights

Under the General Data Protection Regulation (EU) 2017/676, you may have the right (subject to certain limitations) to:

Rights	Details
Right of access	You have the right to obtain from us confirmation as to whether your personal data are being processed, and, where that is the case, access to such personal data.
Right to Rectification	We will use reasonable endeavors to ensure that your personal data is accurate. In order to assist us with this, you should notify us of any changes to the personal data that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete.
Right to withdraw consent	You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Right to erasure / ‘Right to be forgotten’	Asking us to delete all of your personal data will result in us deleting your personal data without undue delay (unless there is a legitimate and legal reason why we are unable to delete certain of your personal data, in which case we will inform you of this in writing).
Right to restriction of processing	You have the right to ask us to stop processing your personal data at any time.
Right to data portability	You have the right to request that ContactEngine Limited provides you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so.
Right to complain	You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner’s Office in the UK (see www.ico.org.uk). Although we encourage our customers to engage with us in the event they have any concerns or complaints. You can do so by writing to us at support@contactengine.com.

All of these rights can be exercised by contacting us at support@contactengine.com.

ContactEngine Limited will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above. However, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data this will usually be free of charge. However, any further copies requested may be subject to reasonable fees based on administrative costs.

Where you request us to rectify or erase your personal data or restrict any processing of such personal data, we may notify third parties to whom such personal data has been disclosed of such request. However, such third party may have the right to retain and continue to process such personal data in its own right, for example your school may be permitted to continue to process your personal data on other lawful grounds without your consent.

Changes to this notice

Any changes we make to this notice in the future will be posted on this page and, where appropriate, we will notify you, by email, or by means of a notice on our home page. Your continued use of ContactEngine, including use after the posting of any changes to these terms, will be deemed acceptance by you of the notice. The date the notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this notice to check for any changes.

	Personal data collected	Why personal data are processed	Legal basis for processing	Period for which your data will be stored	Will your personal data will be shared with third parties?	Transfers outside the European Economic Area
1.	The IP address or other identifier of the device you used to access ContactEngine.	To improve the function of ContactEngine.	Processing is necessary for the legitimate interests of ContactEngine Limited (i.e. to understand how ContactEngine is being used).	1 week	Unless we are otherwise legally required, we may share this data with an analytics provider to help us improve ContactEngine.	No
2.	Your name and email address.	To enable you to use ContactEngine.	Please check with our client or partner.	Unless we are otherwise legally required, we hold this data in accordance with our client or partner’s instructions.	Not unless we are legally required to do so.	No
		To notify you about changes to our service.	Please check with our client or partner.	Unless we are otherwise legally required, we hold this data in accordance with our client or partner’s instructions.	Not unless we are legally required to do so.	No
		To enable use to enforce our End User Access Agreement.	Processing is necessary for the legitimate interests of ContactEngine Limited (i.e. to ensure the protection of its business.	A maximum of 6 years	Not unless we are legally required to do so.	No
3.	A record of any communication / correspondence you have with us (e.g. when you contact us by email, telephone or post).	To enable us to effectively communicate with you.	Processing is necessary for the legitimate interests of ContactEngine Limited (i.e. to understand how ContactEngine is being used).	A maximum of 6 years	Not unless we are legally required to do so.	No
4.	Any personal data that you provide to us as part of a survey.	To improve ContactEngine.	Processing is necessary for the legitimate interests of ContactEngine Limited (i.e. to understand the requirements of our potential and actual clients).	A maximum of 6 years	Unless we are otherwise legally required, we may share this data with an analytics provider to help us improve ContactEngine.	No