Privacy Policy
East Meets West Direct - Privacy Policy
Last updated: December 15th, 2022
- Definitions used in this Policy
- Data protection principles we follow
- What rights do you have regarding your Personal Data
- What Personal Data we gather about you
- How we use your Personal Data
- Who else has access to your Personal Data
- How we secure your data
- Information about cookies
- Contact information
- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
| Type(s) of data subject | Categories of personal data | Purpose of processing | Lawful basis |
|---|---|---|---|
| Customers, their employees and contractors | Contact information, including: Name, address, telephone number and e-mail address Communication data including e-mail communication, text and other messaging services Financial data including some limited bank account and payment card details Transaction data including details about payments to and from customers | Provision of products and/or services Transactional and security purposes | Necessary for the performance of a contract |
| Customers, their employees and contractors | Contact information, including name, address, telephone number and e-mail address | Marketing communications, including competitions | Consent OR Soft opt-in in case of existing or previous customers and those enquiring about our products and/or services |
| Suppliers, partners, freelancers and contractors subcontractors and their employees | Contact information, including name, address, telephone number and e-mail address; bank details | To enable compliance with obligations under relevant contracts, including processing order, refunds, logging and payment of invoices. | Necessary for the performance of a contract |
| Business contacts and potential customers | Contact information, including name, company name, job position, address, telephone number and e-mail address, including those available via business networking websites, such as LinkedIn | Business networking and marketing | Legitimate interests of all parties 1. Our and our business contacts’ legitimate interests in order to network in the context of business and provide some marketing information. 2. It is necessary to exchange, keep and otherwise process contact information in order to network in the context of business and provide marketing information. 3. There is normally a positive action taken by all parties to provide their contact details during networking with the expectation that such contact details, including personal data, may be used by the recipient for business networking. For marketing - using personal data made by the data subject in his or her business capacity public by placing their personal data in the public domain the data subject may reasonably expect a certain amount of marketing material. If we collect personal data for marketing purposes in this way, we will always provide a link to our privacy policy and give an opportunity to object to receiving further marketing from us with our every marketing communication. |
| Potential customers | Personal data in business capacity: Contact information, including name, company name, job position, address, telephone number and e-mail address, including those available via business networking websites, such as LinkedIn or business services such as Experian | Marketing, including mailing, emailing and telemarketing | Consent, as obtained by third parties for our benefit, or legitimate business interests. Where legitimate interests are used personal data is obtained in the business capacity from publicly available sources. We use B2B marketing lists provided by Selectabase Ltd and other reputable UK based providers on the basis of their standard terms and conditions that incorporate data protection obligations on both us and the provider. |
We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law. Our general data retention period is 7 years for legal and accounting purposes but we will generally keep your personal data for only as long as we need it, in accordance with our data retention procdures, and we will conduct regular reviews to ascertain whether we need to keep your personal data.
Who else can access your Personal Data
We are allowed to disclose your information in the following cases:
- If we want to sell our business, we can disclose it to the potential buyer.
- We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights.
- We can exchange information with others to protect against fraud or credit risks.
We may contract with third parties to supply our services to you on our behalf. These may include payment processing, search engine facilities, web hosting, advertising and marketing. In some cases, the third parties may require access to some or all of your data. These are the third parties that have access to your information:
- Xero and other accounting and invoicing services, as may be required for our compliance with statutory obligations and financial calculations – identity, contact, financial and transactional data
- Email/webmail, IT and hosting services providers, as may be necessary for the provision of their services to us – identity data, contact data, financial data, transaction data, technical data, profile data, usage data and/or marketing and communications data
- Payment processing companies, as may be necessary for the provision of their services including to be able to process debit and credit card payments – identity data, contact data, financial data and transaction data
- Banks, as may be necessary for the provision of their services to us - identity data, contact data, financial data and transaction data
- Insurance companies, as may be necessary for the provision of their services to us - identity data, contact data, financial data and transaction data
- Debt collection agencies, as may be necessary for the provision of their services to us - identity data, contact data, financial data and transaction data
- Mailchimp and other marketing services/ CRM providers, as may be necessary for the provision of their services to us - identity data, contact data and transaction data
- Social media platforms, such as Facebook, LinkedIn, Instagram and others, to collect initial contact details of a potential customer – identity data and contact data
- Businesses that analyse traffic visiting our site and to support users – identity data and contact data
- Telecommunication services providers, as may be necessary for the provision of their services to us - identity data, contact data, financial data, transaction data, technical data, profile data and usage data
- Parcel tracking services providers, as may be necessary for the provision of their services to us – identity data, contact data and transaction data
- Other services providers, including law firms and documents services – identity data, contact data, financial data and/or transaction data as may be required for the provision of the relevant services
- Governmental authorities, as may be necessary in order for us to comply with statutory requirements and official requests – identity data, contact data, financial data, transaction data, technical data, profile data, usage data, marketing and communication data.
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under UK GDPR and the law.
We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
How we secure your data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use usernames, passwords, encryption, anonymising, pseudonymising and other measures where suitable. We monitor our systems for possible vulnerabilities and attacks.
Even though we try our best we cannot guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret.
We will generally store your personal data within the UK or the European Economic Area (EEA) and we may transfer your collected data to storage or companies based outside of the UK and EEA. It may be processed outside the UK and EEA as may be necessary to provide our products and/or services to you, to deal with payment, or if we have your consent.
We will only transfer your data to countries that are deemed to have an adequate level of protection of personal data by the European Commission; or we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe, such as the relevant version of the Standard Contractual Clauses.
By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
Children
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
Cookies and other technologies we use
We use cookies and/or similar technologies to analyse customer behaviour, administer the website, track users’ movements, and to collect information about users. This is done in order to personalise and enhance your experience with us.
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
We use cookies for the following purposes:
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
- Analytics cookies – these cookies are used to track the use and performance of our website and services
- Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
- You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.
