— Section: United States —

IMPORTANT: BY SUBMITTING DATA TO US AND/OR USING OUR WEB SITE YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA THAT YOU SUBMIT MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED IN THE FOLLOWING PRIVACY POLICY.

GORILLA CORPORATION HOLDINGS INC. is registered in DELAWARE, USA.

Company Number 4914607

Privacy Policy

This Privacy Policy describes GORILLA CORPORATION HOLDINGS’s current policies and practices with regard to Personal Data collected by us manually or through www.gorillaict.com (“Web Site” and any “Subdomains”). The term “Personal Data” refers to personally identifiable information about you, such as your name, birth date, telephone number, e-mail address or mailing address.

Notification of changes to this Policy

We are continually improving and adding new functionality and features to this Web Site and improving and adding to our existing services. Because of these ongoing changes, changes in the law and the changing nature of technology, our data practices will change from time to time. If and when our data practices change, we will (as soon as practicable) post the changes on our Web Site to notify you of the changes. We encourage you to check this page frequently.

Collection of Personal Data including email addresses

We will collect and store the information you give us. You may use this Web Site to register to receive additional information or services from us. When you register, we ask you for contact information like your name, postal address and email address.

We sometimes supplement the information that you provide with information that is received from third parties. For instance, if inaccurate postal or zip codes are received, we may use third party software to fix them.

Use of Personal Data

The purposes for which we process Personal Data include the following:

• We may contact you occasionally to inform you of new services we will be providing, or events or articles we think will be of interest to you.
• We may use your Personal Data to contact you regarding fundraising, support and friendship to our charity.
• We may use your Personal Data internally to help us improve our services and to help resolve any problems.

Opt-out choice

If you do not wish to receive information from us and want to be removed from our mailing list, please use the Contact page.

Anonymous data collected through this Web Site

In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our Website. For example, we use technology to track which pages of our Web Site our visitors view. We also use technology to determine which Web browsers our visitors use. This technology does not identify you personally, it simply enables us to compile statistics about our visitors and their use of our Website.

Our Web Site contains hyperlinks to other pages on our Website. We use technology to track how often these links are used and which pages on our Web Site our visitors choose to view. Again this technology does not identify you personally – it simply enables us to compile statistics about the use of these hyperlinks.

We use this anonymous data to improve the content and functionality of this Website and our email updates, to better understand our clients and markets, and to improve our services.

Cookies

In order to collect the anonymous data described in the preceding paragraph, we may in the future use temporary “cookies” that collect the first level domain name of the user (for example, if your email address is “tony@bluage.com,” the cookie collects the “bluage.com” portion of your email address) and the date and time you accessed this Web Site. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to your browser and stored on your computer”s hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not.

We also use your IP address to help diagnose problems with our server and to administer our Web Site. An IP address is a numeric code that identifies your computer on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information, such as determining how many of our visitors are from outside of the USA.

We may also perform IP lookups to determine which domain you are coming from (i.e.: aol.com, yourcompany.com) to more accurately gauge our users’ demographics.

Disclosure of your Personal Data

We do not share, sell or distribute your Personal Data with unrelated third parties, except under these limited circumstances:

• Personal Data may occasionally be transferred to third parties who act for us for further processing in accordance with the purposes for which the data was originally collected or for purposes to which you have subsequently consented.
• We may share or transfer the information in our databases to comply with a legal requirement, for the administration of justice, to protect your vital interests, to protect the security or integrity of our databases or this Web Site, to take precautions against legal liability, or in the event of a sale, merger, reorganisation, dissolution or similar event.
• We may share or transfer the information in our databases with and to our volunteers, advisers and also external law firms in order to service your needs who may have their own privacy policy to which you may then be subject.

Where appropriate, before disclosing Personal Data to a third party, we contractually require the third party to take adequate precautions to protect that data and maintain confidentiality.

Data integrity and security

We strive to maintain the reliability, accuracy, completeness and currency of Personal Data in our databases and to protect the privacy and security of our databases. We keep your Personal Data only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.

Our employees and counselors who have access to Personal Data have been trained to handle such data properly and in accordance with our security protocols and strict standards of confidentiality. Although we cannot guarantee against any loss, misuse, unauthorized disclosure, alteration or destruction of data, we try to prevent such unfortunate occurrences.

Data access and corrections

Upon receipt of your written request and enough information to permit us to identify your Personal Data, we will disclose to you the Personal Data we hold about you. We will also correct, amend or delete any Personal Data that is inaccurate and notify any third party recipients of the necessary changes.

If you wish to access or correct your Personal Data, please write to us at:

GORILLA CORPORATION HOLDINGS INC. (USA)

Global Corporate Services, Inc. Acme Filings Corp.704 N. King Street Suite 500 P. O. Box 1031 Wilmington, DE 19899 County of New Castle U.S.A.

We do not charge for complying with a correction request. Requests to delete Personal Data are subject to any applicable legal and ethical reporting or document retention obligations imposed on us.

Link to other websites

This Web Site contains hyperlinks to web sites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party web sites or any association with their operators. We do not control these websites and are not responsible for their data or privacy practices. We urge you to review any privacy policy posted on any site you visit before using the site or providing any Personal Data about yourself.

Transfer of data abroad

We do not intentionally transfer Personal Data outside the USA.

Of course, the Internet is made up of a large number of international connections. If you are visiting this Web Site from a country other than the country in which our server is located (currently USA), the various communications will necessarily result in the transfer of information across international boundaries. By visiting this Web Site and communicating electronically with us, you consent to these transfers.

Governing Law

This privacy policy forms part of our Website Terms of Use and as such shall be governed by and construed in accordance with the laws of DELAWARE, USA. You agree to submit any dispute arising out of your use of this Web Site to the exclusive jurisdiction of the courts of DELAWARE, USA.

Questions

If you have any questions about this Privacy Policy or concerns about the way we process your Personal Data, please contact us by using the Contact Page

— Section: Europe —

8 Digital Marketing t/a Gorilla Corporation

This Privacy Policy sets out how we, 8 Digital Marketing Ltd, collect, store and use information about you when you use or interact with our website, http://8-digital.com (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 15th May 2018.

Contents[1]

• Summary
• Our details
• Information we collect when you visit our website
• Information we collect when you contact us
• Information we collect when you interact with our website
• How we collect or obtain information about you from third parties
• Disclosure and additional uses of your information
• How long we retain your information
• How we secure your information
• Transfers of your information outside the European Economic Area
• Your rights in relation to your information
• Your right to object to the processing of your information for certain purposes
• Sensitive Personal Information
• Changes to our Privacy Policy
• Children’s Privacy
• California Do Not Track Disclosures
• Copyright, credit and logo

Summary

This section summarizes how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

• Data controller: 8 Digital Marketing Ltd
• How we collect or obtain information about you:
  • when you provide it to us (e.g. by contacting us) by:- Instructing us to provide services to you, when you have provided a contact email to receive occasional industry updates
  • from your use of our website, using cookies, and
  • occasionally from third parties where you have opted in and allowed transfer of data to third parties. .
• Information we may collect: Business name, contact name and contact details, VAT number if applicable, IP address, information from cookies (e.g. device and browser type, information about which pages of our website you have viewed, the time when you viewed them and what you clicked on, the geographical location from which you accessed our website based on your IP address). In addition to this we may collect any other information necessary to perform and or provide any service that you have instructed us to carry out on your behalf.
• How we use your information: To fulfill any contractual obligations we have entered into with you, for administrative and business purposes (particularly to contact you), to improve our business and website, to analyse your use of our website, to fulfill our legal obligations, to provide you with information relevant to the security/effectiveness/visibility of your company website
• Disclosure of your information to third parties: only to the extent necessary to run our business, to fulfill any contracts we enter into with you, where required by law or to enforce our legal rights.
• Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): NO, we do not sell your information.
• How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
• How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.
• Use of cookies: we use cookies on our website including essential cookies used for analytics and traffic purposes and functional cookies to measure conversions to thank you pages.
• Transfers of your information outside the European Economic Area: We will only transfer your information outside the European Economic Area if we are required to do so by law OR where it is necessary to fulfill the contractual obligations entered into with you. Where we do so, we will ensure appropriate safeguards are in place (including ensuring that the third parties used have appropriate safeguards in place)
• Your rights in relation to your information
  • to access your information and to receive information about its use
  • to have your information corrected and/or completed
  • to have your information deleted
  • to restrict the use of your information
  • to receive your information in a portable format
  • to object to the use of your information
  • to withdraw your consent
  • to the use of your information (subject to legal obligations)
  • to complain to a supervisory authority
• Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about yourself to us. For more information, please see the main section below entitled Sensitive Personal Information

Our details

The data controller in respect of our website is 8 Digital Marketing Ltd (company number: 07052026 of Warwick Technology Park, Gallows Hills, Warwick CV34 6UW. You can contact the data controller by writing to the above address or sending an email to support@8-digital.com

If you have any questions about this Privacy Policy, please contact the data controller.

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

Web server log information

We use a third party[2] server to host our website called GoDaddy, their privacy policies are available here: https://uk.godaddy.com/agreements/showdoc.aspx?pageid=PRIVACY. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the date and time of the request and the source of your access to our website (e.g. the website or URL (link) which referred you to our website.

Use of website server log information for IT security purposes

Our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analyzing log files to help identify and prevent unauthorized access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

We do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Le

gitimate interests: we and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.

Use of website server log information to analyse and improve our website

We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit, the operating system and browser used.

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including: essential, functional, analytical and targeting cookies. For further information on how we use cookies, please see our Use of cookies section.

You can reject some or all of the cookies we use on or via our website by changing your browser settings or, for non-essential cookies, by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to inquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third party email provider is 1&1. Their privacy policy is available here: https://www.1and1.co.uk/terms-gtc/terms-privacy/?linkId=ft.nav.privacypolicy.

Emails you send us will be stored within the European Economic Area on our 1&1 servers in the United Kingdom of Great Britain and Northern Ireland. For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.]

Contact form

When you contact us using our contact form, we collect: Your name, email, company, subject and message. We also collect any other information you provide to us when you complete the contact form e.g. if you are happy for us to contact you for marketing purposes.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your inquiry.

If you do not supply the optional information required by our contact form, you will not be able to make the most of 8-digital’s promotion content and offers.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to inquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Messages you send us via our contact form will be stored within the European Economic Area on our 1&1 servers in the United Kingdom of Great Britain and Northern Ireland where your third party provider stores your emails. Our third party email provider is 1&1. Their privacy policy is available here: https://www.1and1.co.uk/terms-gtc/terms-privacy/?linkId=ft.nav.privacypolicy

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.[3]

Telephone

When you contact us by telephone, we will, if necessary for the provision of our service to you, collect your telephone number and any information provided to us during your conversation with us.

We do not record telephone conversations

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to inquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so)

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service provider, The Colin Sanders Innovation Centre, Banbury.

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to inquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Information we collect when you visit with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Contact Form

When you complete a contact form on our website, we collect the following information: Your name, company, website, telephone number and contact email and any other information you provide to us when you complete the contact form.

Legal basis for processing: to carry out the function(s) (e.g to contact you) you have requested on the contact form.

Transfer and storage of your information

Information you submit to us via the registration form on our website will be stored within the European Economic Area on our 1&1 servers in the United Kingdom of Great Britain and Northern Ireland where your third party provider stores your emails. Our third party email provider is 1&1. Their privacy policy is available here: https://www.1and1.co.uk/terms-gtc/terms-privacy/?linkId=ft.nav.privacypolicy

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Marketing communications

You can opt-out from receiving marketing communications in relation to our services by emailing 8-digital at support@8-digital.com with the subject line “UNSUBSCRIBE”.

We may send you marketing communications in relation to similar services if you do not opt out from receiving them.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: direct marketing and advertising our products and services.

Transfer and storage of your information

We use a third party service to administer our mailing list, MailChimp

For more information about our third party mailing list provider, please see their privacy policy which is available here: https://mailchimp.com/legal/privacy/.

Our goods and services

You can opt in to receiving email marketing communications from us in relation to our goods and services by ticking a box indicating that you would like to receive such communications in our cookies box at the bottom of the web browser page. Titled “This website uses cookies”.

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties. The third parties from which we may receive information about you will generally include affiliates or business partners.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a subcontract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we may obtain information about you from certain publicly accessible sources, both EU and non-EU, such as: the electoral register, Companies House, media publications, social media, and websites (including your own website if you have one

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.

For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: we may obtain information from third parties, such as data brokers, where you have consented to them sharing information with us by

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:[4]

• Telephone provider(s), including Colin Sanders Innovation Centre. Their privacy policy is available here: http://www.colin-sanders-bic.co.uk/privacy-policy/
• Email provider(s), including 1&1. Their privacy policy is available here: https://www.1and1.co.uk/terms-gtc/terms-privacy/?linkId=ft.nav.privacypolicy
• Web developer(s), including Flexi IT].
• Hosting provider(s), including GoDaddy or Simple Servers. Their privacy policy is available here: https://uk.godaddy.com/agreements/showdoc.aspx?pageid=PRIVACY & https://www.simpleservers.co.uk/privacy-policy

Our third party service providers are located apart from Flexi IT, which are located in Ukraine, our service providers are located The United Kingdom of Great Britain and Northern Ireland.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest relied on: where we share your information with these third parties in a context other than where it is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc & Facebook. [Google &Facebook collect information through our use of Google Analytics on our website And through retargeting for Facebook should it be accepted. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/][5]

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.]

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, and insurers. Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business efficiently.

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.]

Our accountants are Ashby Dale Ltd, of Moreton Pinkney, Daventry, NN11 3SG

Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.]

Our insurers are Hiscox. Their privacy policy is available here: https://www.hiscox.co.uk/cookies-privacy.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business effectively.

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): resolving disputes and potential disputes.

 For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Server log information: we retain information on our server logs for up to 5 years.

Correspondence and inquiries: when you make an inquiry or correspond with us for any reason, whether by email or via our contact form, [or by phone, we will retain your information for as long as it takes to respond to and resolve your inquiry, and for 12 further month(s) after which point we will delete your information.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

• [the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
• whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
• whether we have any legal basis to continue to process your information (such as your consent);
• how valuable your information is (both now and in the future);
• any relevant agreed industry practices on how long information should be retained;
• the levels of risk, cost and liability involved with us continuing to hold the information;
• how hard it is to ensure that the information can be kept up to date and accurate; and
• any relevant surrounding circumstances (such as the nature and status of our relationship with you).][6]
  
  

 How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:

• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
• Using secure servers to store your information.
• verifying the identity of any individual who requests access to information prior to granting them access to information;
• Using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website.
• Only transferring your information via closed system or encrypted data transfers.
  
  

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.[7]

Transfers of your information outside the European Economic Area

All of your information is stored in the following European Economic Area (EEA) countries: United Kingdom of Great Britain and Northern Ireland

Other than to comply with any legal obligations to which we are subject (compliance with a court order, for example), we do not intend to transfer your information outside the EEA or to an international organisation. In the unlikely event that we are required to transfer your information outside the EEA (or to an international organisation) for such a purpose, we will ensure appropriate safeguards and protections are in place.

 Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to support@8-digital.com.

• to request access to your information and information related to our use and processing of your information;
• to request the correction or deletion of your information;
• to request that we restrict our use of your information;
• to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that
• information transferred to another data controller (including a third party data controller);
• to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
• to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
  
  

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

• https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
• https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
  
  

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

 How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identify you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to 8 Digital Marketing Ltd, Warwick Technology Park, Gallows Hills, Warwick CV34 6UW. You can contact the data controller by writing to the above address or sending an email to support@8-digital.com

• to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analyzing or predicting your behavior based on your information) based on any of these purposes; and
• to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).
  
  

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

• clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
• sending an email to support@8-digital.com], asking that we stop sending you marketing communications or by including the words “OPT OUT”.
  
  

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies.

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to support@8-digital.com

California Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as analytics tags and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, email support@8-digital.com with the subject line “UNSUBSCRIBE”.

 Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Safeguards for overseas transfers

• [an adequacy decision by the European Commission. This is permitted under Article 45(1) of the General Data Protection Regulation. The adequacy decision relied on by us is and is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm]
• [data protection policies adhered to by the data controller and other companies and entities within our corporate group from time to time, which comply with applicable laws, known as “binding corporate rules” or “BCRs” under Article 47 of the General Data Protection Regulation. This is permitted under Article 46(2)(b) of the General Data Protection Regulation. [These policies are available here]
• standard data protection clauses adopted by the European Commission in accordance with its committee examination procedure under Article 93(2) of the General Data Protection Regulation. This is permitted under Article 46(2)(c) of the General Data Protection Regulation. [These clauses are available here]
• standard data protection clauses adopted by the Information Commissioner’s Office and approved by the European Commission pursuant to the committee examination procedure under Article 93(2) of the General Data Protection Regulation. This is permitted under Article 46(2)(d) of the General Data Protection Regulation. [These clauses are available here]
• an approved code of conduct under Article 42 of the General Data Protection Regulation. This is permitted under Article 46(2)(f) of the General Data Protection Regulation. [This code of conduct is available here]
• [insert name of certification mechanism e.g. EU-U.S. Privacy Shield], an approved certification mechanism under Article 42 of the General Data Protection Regulation. This is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access it here:  [and the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm][8].