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PRIVACY NOTICE

ENGYS understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits Our website blog.engys.com (herein referred to as Our Site) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under applicable data privacy laws.

Please read this Privacy Notice carefully and ensure that you understand it. Your acceptance of this Privacy Notice is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Notice, you must stop using Our Site immediately.

ENGYS Blog Privacy Notice (blog.engys.com) – 7 May 2020


1. Definitions and Interpretation

In this Privacy Notice, the following terms shall have the following meanings:

Account means an account required to access and/or use certain areas and features of Our Site;
Cookie means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in our Cookie Policy, as described in Clause 13 below;
Personal data means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (GDPR);
ENGYS/We/Us/Our means (i) ENGYS Ltd., a company registered in England and Wales under 6936178, whose registered address is 1 The Green, Richmond, Surrey, TW9 1PL, UK and whose main trading address is Studio 20, Royal Victoria Patriotic Building, John Archer Way, London, SW18 3SX, UK, and (ii) all its subsidiary companies:

In the context of lawful basis:

Legitimate Interests means the interest of Our business in conducting and managing Our business to enable Us to give you the best products and services and the best and most secure experience. We make sure We consider and balance any potential impact on you (both positive and negative) and your rights before We process your personal data for Our Legitimate Interests. We do not use your personal data for activities where Our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how We assess Our Legitimate Interests against any potential impact on you in respect of specific activities by contacting Us using the details provided in Clause 14;
Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract;
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that We are subject to;

In the context of third parties:

Internal Third Parties means all the subsidiary companies of ENGYS Ltd. listed above acting as joint controllers and who provide general support, IT and system administration services and undertake leadership reporting; and
External Third Parties means all and any of the following:

2. Purpose of This Privacy Notice

This Privacy Notice aims to give you information on how We collect and processes your personal data through your use of Our Site.
Our Site may include links to other websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave Our Site, we encourage you to read the privacy notice of every website you visit.
Our Site is not intended for children and we do not knowingly collect data relating to children.

3. Your Legal Rights

As a data subject, you have the right to be informed about Our collection and use of personal data under applicable data privacy laws such as the GDPR (which this Privacy Notice has been designed to uphold). You also have the right to:

If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in Clause 14 and We will do our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with a competent local supervisory authority, such as the Information Commissioner’s Office in the UK or the equivalent body in other EEA states.

4. What Data Do We Collect?

Depending upon your use of Our Site, We may collect, use, store and transfer different kinds of personal data about you which We have grouped together as follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in the law as this data does not directly or indirectly reveal your identity. For example, We may aggregate your Usage Data to calculate the percentage of users accessing a specific feature in Our Site. However, if We combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, We treat the combined data as personal data which will then be used in accordance with this Privacy Notice.
We do not collect any Special Categories of Personal Data about you (this includes: details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do We collect any information about criminal convictions and offences.

5. How is Your Data Collected?

We use different methods in Our Site to collect data from and about you, including through:

Direct interactions

We collect your Identity, Contact, Profile and/or Marketing and Communications Data when you create an Account in Our Site using the services provided by Disqus to leave comments in our blog posts, or when you complete a web form in Our Site to receive updates from Us.

Automated technologies or interactions

As you interact with Our Site, We may automatically collect Technical and Usage Data about you. We collect this data by using different Cookies, server logs and other similar technologies. We may also receive Technical and Usage Data about you if you visit other websites employing our Cookies. Please refer to Clause 13 below for further details.
We also collect Technical Data and Usage Data about you whenever you receive and open one of Our marketing emails. We collect this data automatically using analytics services provided by Zoho Corporation in the US.

6. How Do We Use Your Data?

Our use of your personal data will always have a lawful basis, either (i) because it is necessary for Our Performance of a Contract with you, (ii) because it is in Our Legitimate Interests, or (iii) because We need to comply with a legal or regulatory obligation.
Generally, We do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you by email.
More specifically, We may use the data We collect from you through Our Site for the following purposes:

We may also use your Identity, Contact, Technical, Usage and Marketing and Communications Data for marketing purposes, which may include contacting you by email with information, news, events and offers on Our products and/or services.
You will receive marketing emails from Us through the use of Our Site if (i) you have subscribed in Our Site to receive Our updates or (ii) you have created an Account and, in each case, you have not opted out from receiving Our communications. We will never send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the applicable data privacy laws.
You can opt out at any time from receiving Our marketing communications by using the Unsubscribe link provided with all Our marketing emails. Where you opt out of receiving Our marketing messages, this will not apply to personal data provided to Us as a result of a product/service purchase, product/service experience or other similar transactions
We will only use your personal data for the purposes for which We collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. If We need to use your personal data for an unrelated purpose, We will notify you and We will explain the legal basis which allows us to do so.
Please note that We may process your personal data without your knowledge or consent, in compliance with the rules set out in this Privacy Notice, where this is required or permitted by law.

7. How and Where Do We Store Your Data?

Some or all of the data We collect from you may be stored outside of the UK or the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the UK or EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR, including at least one of the following safeguards:

8. Do We Share Your Data?

We may have to share your personal data with the parties listed below for the purposes set out above in Clause 6:

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow External Third Parties to use your personal data for their own purposes, and only permit them to process your personal data for specified purposes and in accordance with Our instructions.
Many of Our Internal Third Parties and External Third Parties are located outside the UK and EEA. Where We transfer any personal data outside the UK and EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and EEA (under the GDPR) by implementing the same safeguards listed above in Clause 7.
We do not sell, trade or rent your personal data information to others.
Please contact Us using the details provided in Clause 14 if you need further information on the specific mechanisms We use to transfer your personal data out of the UK, EEA or your country of residence.

9. Data Security

Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to your personal data to those employees, Internal Third Parties and External Third Parties who have a business need to know. They will only process your personal data on Our instructions and they are all subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and We will notify you and any applicable regulator of a breach where We are legally required to do so.

10. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal or business requirements.
To determine the appropriate retention period for personal data, We consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which We process your personal data and whether We can achieve those purposes through other means, and the applicable legal requirements.
By law, We have to keep basic information about our customers (including Contact and Identity Data, as well as sales and financial reports) for at least 10 years after they cease being customers for tax purposes and legal purposes.
In some circumstances you can ask Us to delete your data in accordance with your legal rights, as set out in Clause 3.
In some circumstances We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you.

11. Your Right to Withhold Information

You may access most areas of Our Site without having to release any personal data. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data (for example, We might need to access some of your Profile Data to register your Account).
You may also restrict Our use of Cookies. For more information, please see Clause 13 below.
Where We need to collect personal data by law or under the terms of a contract We have with you, and you fail to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into with you (for example, to provide you with products or services). In this case, We may have to cancel a product or service you have with Us but We will notify you if this is the case at the time.

12. How Can You Access Your Data?

You can contact Us at any time using the details provided in Clause 14 to ask for a copy of any of your personal data held by Us (where such data is held). You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, We may refuse to comply with your request under these circumstances.
We may need to request specific information from you to help Us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up Our response.
We try to respond to all legitimate requests within one month. Occasionally it may take Us longer than a month if your request is particularly complex or you have made a number of requests. In this case, We will notify you and keep you updated.

13. Our Use of Cookies

We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and/or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data are protected and respected at all times.

Cookie law states that we can store Cookies on your computer or device if they are strictly necessary for the operation of Our Site. For all other types of Cookies we need your consent.

For more details about Our use of Cookies, or to change or withdraw your consent, please refer to Our Cookie Policy.

14. Contact Us

We have appointed Our Director of Operations (Francisco J. Campos) as Our data privacy manager, responsible for overseeing all queries in relation to Our Site and this Privacy Notice.
If you have any questions or complaints about Our Site or this Privacy Notice, please contact Our data privacy manager by email at blog@engys.com, by telephone on +44 (0)20 3239 3041, or by post at ENGYS Ltd., Studio 20, Royal Victoria Patriotic Building, John Archer Way, London, SW18 3SX, UK. Please ensure that your query is clear, particularly if it is a request for information related to the data We hold about you (as described in Clause 4).

15. Changes to Our Privacy Notice

The date on which this Privacy Notice was last updated appears at the head of this page. We may change this Privacy Notice from time to time and without any notice given (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Notice on your first use of Our Site following the alterations. On this basis, We recommend that you check this page regularly to stay up to date.
In the event of any conflict between the current version of this Privacy Notice and any previous version(s), the provisions current and in effect shall prevail unless it is expressly stated otherwise.
It is important that the personal data We hold about you is accurate and current. Please keep Us informed if your personal data changes during your relationship with Us.