ContactEngine Limited Privacy Policy

Date: 22.03.2018

About this Privacy Policy

ContactEngine Limited (“we”, “us”, “our”, “ours”, “ContactEngine Limited”) respects your privacy and is committed to protecting it through compliance with this Policy.  This Policy applies only to (i) activities on or through our public Website www.contactengine.com (the “Website”) and (ii) our direct marketing activities.  It does not apply to the use of our software-as-a-service conversation engine (“ContactEngine”), nor to activities offline.  If you have been authorized by a client or partner of ours to use ContactEngine, 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 controller (i.e. the person that determines the purposes and manner in which your personal data are processed) is ContactEngine Limited.  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 Privacy Policy are welcome and should be addressed to support@contactengine.com.

Information we may process about you

Our Website operates primarily to market ContactEngine to other businesses.  To the extent we collect personal data via this Website, our main purpose is to better serve our business clients and their employees and to improve the function of the Website.  We may also obtain personal information from one or more specialist market research partners – we do so to send relevant information about our products and services.  A breakdown of the personal data we may process about you is set out at the end of this Policy.

Our Website may contain links to third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third-party websites.

How personal data are collected

We may obtain personal data about you in three main ways:

  • You provide us with your personal data (such as when you tell us your name and email address via the Website).
  • Personal data is collected automatically (such as the automatic recognition of your IP address or placement of cookies on your device).
  • Personal data is collected, and provided to us, by a third party (such as by a specialist market research provider).

IP Addresses

The Website servers automatically recognize visitors’ IP addresses (the number assigned to computers on the Internet), domain names, the activity of the visitor’s browser when the visitor is viewing the Website; the site path of visitors; the time visitors come to the Website; and length of visit.  The Website may also gather anonymous traffic data that does not personally identify you, but that may be helpful for marketing purposes or for improving the services we offer.  We reserve the right to publish such anonymous, aggregate summary information regarding visitors for promotional purposes.

Cookies and web beacons

We use cookies and web beacons to distinguish you from other users.  This helps us provide you with a good experience when you use our Website.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.  Cookies contain information that is transferred to your computer’s hard drive.

A web beacon achieves a similar outcome to a cookie, allowing us to understand that you have accessed our content. Where cookies store content to your computer's hard drive, web beacons store information on a remote server.

We use the following cookies and web beacons:

  • Strictly necessary cookies.  These are cookies that are required for the operation of our Website.
  • Analytical/performance cookies.  They allow us to recognize and count the number of visitors and to see how visitors move around our Website and when they are using it.  This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.  For example, the cookies relating to Google Analytics is a performance / analytical cookie.
  • Functionality cookies.  These are used to recognize you when you return to our Website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies.  These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising information displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.  These cookies are likely to be analytical/performance cookies or targeting cookies.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.  However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.

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

For information about the cookies the various systems we use to deliver our web site please see the table below.

System

Purpose

More information

Google Analytics

Tracks visitors to our website, allowing us to improve design, functionality and content

https://support.google.com/analytics/answer/6004245

Linkedin Insights

Tracks visitors to our website, allowing us to target advertising to them on the Linkedin platform

https://www.linkedin.com/legal/cookie-policy

Google Adwords

Tracks visitors to our website, allowing us to target advertising to them on the Google advertising platform

https://adssettings.google.com/authenticated, http://optout.networkadvertising.org/#!/

Google Tag Manager

Delivers cookies and web beacons to our webpages for the other systems mentioned here

https://www.google.com/policies/privacy/

A1Webstats

Identifies visitors to our website via their company networks

https://www.a1webstats.com/cookies/

Pardot Tracking Code

Tracks visitor activity within our website and other systems such as emails, allowing us to better target our content development and thought leadership

https://help.salesforce.com/articleView?id=pardot_basics_cookies.htm&type=5

 Children under the age of 16

PLEASE NOTE:  The Website is a general audience site for business employees, and we do not direct any of our content specifically at children under 16 years of age.  We understand and are committed to respecting the sensitive nature of children’s privacy online.  We do not knowingly collect personal information from children under 16.  If you are under 16, do not use or provide any information through the Website.  If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under 16, please contact us at support@contactengine.com.

Where we store your personal information

Unless otherwise described in this Policy, the personal data we collect from you is stored in the European Economic Area ("EEA"). This data may also be processed by staff operating outside of the EEA who work for us or for one of our business partners or service providers.  Further information is provided in the table at end of this Policy.  Please contact us at support@contactengine.com if you would like further details on the specific safeguards applied to the export of your personal data outside the EEA.

Disclosure of your information

In addition to the disclosure described at the end of this Policy, 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 visiting the Website));
  • if you request we do so (lawful ground: you have provided your consent);
  • 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 Website terms (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 have the following rights (subject to certain limitations):

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 policy

Any changes we make to our Privacy Policy 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 the Website, including use after the posting of any changes to these terms, will be deemed acceptance by you of the Privacy Policy.  The date the Privacy Policy 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 Privacy Policy to check for any changes.

 

 

Personal data collected

Why personal data are collected

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 of the device you used to access our Website.

To improve the function of the Website.

Processing is necessary for the legitimate interests of ContactEngine Limited (i.e. to understand who is visiting the Website).

6 months

We may share this data with Google Analytics, Linkedin, Salesforce, Pardot and A1Webstats to help us improve our Website.

 

Google Analytics, Linkedin and/or A1Webstats may store data in the USA.

We rely on the fact that these organisations are certified as complying with Privacy Shield.

2.     

Your name and email address.

To enable us to contact you / send information that you have requested.

You have provided your consent.

For as long as we send you relevant information.

We may use hosted services (such as Salesforce and Pardot) to store your personal information.

We may share this data with one of our group companies if it serves the territory in which you are based.

We may transfer your data to ContactEngine Inc., an entity based in the US. To lawfully do so, we rely on the Model Clauses.

To enable us to engage in direct marketing for products and/or services provided by us that we believe will be of interest to you.

Processing is necessary for our legitimate interests (i.e. direct marketing activities).

Until such time as you inform us you don’t want to continue receiving marketing communications – you have the right to unsubscribe at any time.

We may use hosted services (such as Salesforce and Pardot) to store your personal information.

We may share this data with one of our group companies if it serves the territory in which you are based.

We may transfer your data to ContactEngine Inc., an entity based in the US. To lawfully do so, we rely on the Model Clauses.

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 maintain records with our potential and actual clients. 

Processing is necessary for the legitimate interests of ContactEngine Limited (i.e. to understand who is visiting the Website).

6 years

No

No

4.     

Any personal data provided on a CV / resume provided to us (e.g. via email or through our “Careers” webpage).

To enable us to consider your application.

You have provided your consent.

24 months

We may share this data with ContactEngine Inc. if we think you are interested in applying for a job role outside the UK.

We may transfer your data to ContactEngine Inc., an entity based in the US. To lawfully do so, we rely on the Model Clauses.

5.     

Any personal data that you provide to us as part of a survey.

To improve our Website or services.

Processing is necessary for the legitimate interests of ContactEngine Limited (i.e. to understand the requirements of our potential and actual clients).

6 years

No

 

No