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[Matilda Equiluz]

12 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

2.1 In this Section 2 we have set out: (a) the general categories of personal data that we may process; (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; (c) the purposes for which we may process personal data; and (d) the legal bases of the processing.

2.2 We may process data about your use of our website and services (usage data). The usage data may include your IP address, Company name, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services and for marketing purposes.

2.3 We may process your account data (account data). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and us and/or taking steps, at your request, to send you marketing information.

2.4 We may process your personal data that are provided in the course of the use of our services (service data). The service data may include your name, job title, email address and telephone number. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the pursuit of our legitimate interests, or the proper administration of our website and business.

2.5 We may process information that you post for publication on our website or through our services (publication data). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.6 We may process information contained in any enquiry you submit to us regarding goods and/or services (enquiry data). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.7 We may process information relating to our customer relationships, including customer contact information] (customer relationship data). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is the pursuit of our legitimate interests, or the proper management of our customer relationships

2.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (transaction data). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, in pursuit of our legitimate interests, or the proper administration of our website and business.

2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (notification data). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.10 We may process information contained in or relating to any communication that you send to us (correspondence data). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users. 2.10 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is the pursuit of our legitimate interests, or the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.11 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining professional advice. The legal basis for this processing is the pursuit of our legitimate interests, or the proper protection of our business against risks.

2.12 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3 We may disclose correspondence data to our suppliers or subcontractors identified at[EC1] [EC2] /about-embridge/partners/insofar as reasonably necessary for Marketing purposes, where you have requested information on their products or services or in pursuit of our legitimate interests.

3.4 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.6 Embridge obtains and processes contact data as part of its contracted services to channel partner organisations and their customers or to direct customers. Any processing is strictly in line with Data Protection Act 2018 and for legitimate business purposes or legal / contractual obligations for the execution of contractual requirements.

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA). a) Your personal information may be stored and processed outside of the country where it is collected, including outside of the European Economic Area. When transferring information to others, within the EEA or otherwise, we ensure that appropriate and suitable safeguards and technical measures are in place to protect your personal data. To do this, we make use of standard contractual clauses that have been approved by the European Commission, or we use an appropriate Privacy Shield certification or Binding Corporate Rules put in place by our suppliers, or we implement other similar measures required by laws around the world

4.2 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5.1 This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.3 We will only keep records of your personal information for as long as is reasonably necessary for the purposes for which we have collected it, and in order to comply with any statutory or regulatory obligations in relation to retention of records. We respect requests to stop processing your personal data for marketing purposes. This includes keeping a record of your request indefinitely so that we can respect your request in the future.

5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

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