Uses made of this information

We use information held about you in the following ways:

Information you give to us

We will use this information:

• To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;

• To provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;

• To notify you about changes to our Services;

• To ensure that content from our site is presented in the most effective manner for you and for your computer;

• To request feedback from you to improve our Services.

Information we collect about you

We will use this information:

• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• To improve our site to ensure that content is presented in the most effective manner for you and for your computer;

• To allow you to participate in interactive features of our service, when you choose to do so;

• As part of our efforts to keep our site safe and secure;

• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

• To make suggestions and recommendations to you and other users of our site about products or services that may interest you or them;

• To resolve any problems that your report to us (troubleshooting).

Information we receive from other sources

• We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information

We may share your information with selected third parties (including third parties outside of the EU) for the purpose of:

• processing a subscription, or otherwise in relation to fulfilling a transaction you have made via our Services (Legal basis for processing: Processing is necessary for the performance of a contract);

• for customer services where you may have a query or complaint regarding the Services (Legal basis for processing: Processing is necessary for the performance of a contract and/or legitimate interest);

• for marketing services where you have consented to receive such marketing services (Legal basis for processing: Processing is conducted based on consent);

• for processing payment (including fraud screening) (Legal basis for processing: Processing is necessary for the performance of a contract and legitimate interest);

• collecting your comments if you choose to provide feedback through our Website (Legal basis for processing: Processing is conducted based on consent);

• for undertaking any other permitted use of your Personal Information on our behalf (Legal basis for processing: Processing for the purpose of our legitimate interest); and

• sending email invitations to our customers to review the Ecologi platform and our service.

These service providers will only have access to the Personal Information needed to perform the relevant service and may not use your Personal Information for any other purpose. They will also be required to use your Personal Information strictly in accordance with their applicable data protection laws, including maintaining adequate security measures to protect such Personal Information.

We may also share your personal information with legal or regulatory authorities where we are lawfully requested or required to do so.

We may disclose your Personal Information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

• If Ecologi or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;

• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

We take the security of your data very seriously. We employ physical, electronic and administrative security measures to protect the information that we collect about you from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. You acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of personal data, except to the extent we are required to accept such responsibility by the Data Protection Laws.

You should be aware that your data may be transferred, processed and stored outside of your country (including, if you are located in the European Union, outside of the European Union), and that your data may be subject to disclosure as required by applicable law. It may also be processed by staff operating outside the UK or EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your Personal Information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with our Privacy Policy.

Whenever we transfer your personal data out of the UK and/or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

All information you provide to us is stored on secure servers hosted within Amazon Web Services within the European Union or on our encrypted computers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Any payment transactions will be encrypted and processed by our payment service provider. Your use of the payment service provider is governed by their terms which will be linked to prior to making any payment. We do not store the full PAN or any of the following: cardholder name, expiration date and/or service code (“Cardholder Data”) ourselves but this will be securely processed by our payment service provider.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.

• Where our use of the data is unlawful but you do not want us to erase it.

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

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. If you wish to exercise any of the rights set out above, please contact us at hq@ecologi.com.

The CCPA

If you are a resident of California, you have some specific rights concerning your data. You can exercise these rights by contacting us at hq@ecologi.com.

You have the right to know about the personal information we have collected from you, how it is used and how it is shared.

You have the right to delete the personal information we have on you (there are some exceptions to this).

You have the right to opt-out of the sale of your information (We won’t ever sell your information, don’t worry! But we will tell you you still have the right to ask about it).

You have the right to non-discrimination when using these rights under the CCPA.

NO FEE USUALLY REQUIRED

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 could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

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.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Deactivating your account

Upon request from you by going to your profile page on the website, selecting Account, then selecting Manage Subscription and (at the bottom of the page) clicking on the ‘Close my account’ button, we will deactivate your account and render your Personal Information unusable as soon as reasonably possible, in accordance with applicable law. We do retain personal information from closed accounts to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our terms and conditions, and take other actions otherwise permitted by law.