2. When we say ‘we’, ‘us’ or ‘ESAC’ it’s because that’s who we are and we own and run the website.
The type of personal information we collect
4. We collect certain personal information from visitors of our site.
5. The most common types of information we collect include things like: email addresses, location, language, comments, content you direct us via email and web analytics data.
How we collect personal information
6. We collect your email address directly when you provide it to us through the subscription to our newsletter, or we collect some general information with Google Analytics automatically as you navigate through our website.
7. We collect your personal information when you provide it to us when you complete membership registration, register to an event, to an email list, enter a contest, fill out a survey, send us a communication or you attend one of our events.
Personal information we collect about you from others
8. Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular third-party service providers (like Google, LinkedIn), which may provide us with information about you when you link, connect, or log in to your account with the third-party provider and they send us information such as your registration and profile from that service. The information varies and is controlled by that service provider or as authorized by you via your privacy settings at that service provider.
How we use personal information
9. We will use your personal information:
a. Where this is necessary for purposes which are in our legitimate interests. These interests include:
i. operating the website;
ii. providing you with our newsletter and invitations to our events;
iii. updating you with operational news and information about our website and services e.g. to notify you about changes to our website, website disruptions or security updates;
iv. carrying out technical analysis to determine how to improve the website and services we provide;
v. monitoring activity on the website;
vi. managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the website or asking for your feedback or whether you want to participate in a survey;
vii. Improving our services, and
viii. providing general administrative and perform functions and activities.
b. Where you give us consent by subscribing to our newsletter:
i. providing you with marketing information about products and services which we feel may interest you through our newsletter; and
c. For purposes which are required by law.
d. For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.
When we disclose your personal information
10. We may disclose personal information to the following recipients:
a. companies that are in the ESAC group;
b. authors of any items or services made available to you, so they can facilitate support and license validation, who may be located in any of the countries our products are available in;
c. subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: website hosting providers; technical and customer support services; recruitment agencies; marketing and analytics services; security and fraud prevention services; subscription management services; payment processing services; identification verification services; and operational tooling services;
d. our professional advisers (lawyers, accountants, financial advisers etc.);
e. regulators and government authorities in connection with our compliance procedures and obligations;
f. a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase;
g. a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;
h. a third party, in order to enforce or defend our rights, or to address financial or reputational risks;
i. a rights holder in relation to an allegation of intellectual property infringement or any other infringement; and
j. other recipients where we are authorized or required by law to do so.
Where we transfer and/or store your personal information
11. We are based in Austria, Europe, so your data will be processed in Europe. Some of the recipients we have described in section 10 above, and to whom we disclose your personal information, are based outside Europe. We do this on the basis of your consent to this policy. In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.
How we keep your personal information secure
12. We store personal information on secure servers that are managed by us and our service providers, and occasionally hard copy files that are kept in a secure location in Europe. Personal information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption where appropriate.
How you can access your personal information
13. You can access some of the personal information that we collect from you. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data. To make an access or correction request, contact our admin using the contact details at the end of this policy.
Marketing Choices regarding your personal information
14. Where we have your consent to do so (e.g. if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.
15. You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our website may not work properly in your case.
Cookies and web analytics
16. When you visit our website, there’s certain information that’s recorded which is generally anonymous information and does not reveal your identity. If you’re logged into your account some of this information could be associated with your account. We’re talking about the following kinds of details:
a. your IP address or proxy server IP address’;
b. the name of your internet service provider is sometimes captured depending on the configuration of your ISP connection;
c the date and time of your visit to the website;
d. the length of your session;
e. the pages which you have accessed;
f. the number of times you access our site within any month;
g. the file URL you look at and information relating to it;
h. the website which referred you to our website; and
i. the operating system which your computer uses.
17. Occasionally, we will use third-party advertising companies to serve ads based on prior visits to our website. For example, if you visit our website, you may later see an add for our products and services when you visit a different Site.
Information about children
19. Our website is not suitable for children under the age of 16 years, so if you are under 16 we ask that you do not use our website or give us your personal information. If you are from 16 to 18 years, you can browse the website but you’ll need the supervision of a parent or guardian to become a registered user. It’s the responsibility of parents or guardians to monitor their children’s use of our website.
Information you make public or give to others
How long we keep your personal information
When we need to update this policy
22. We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.
23. When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.
How you can contact us
24. If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact us at firstname.lastname@example.org.
If you’re a user or visitor in the European Economic Area these rights also apply to you:
1. For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.
How you can access your personal information
2. You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.
3. These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.
4. Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.
5. If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
European Super Angels Club, effective date 25 May 2018