ADZY PRIVACY POLICY

Last updated 6th December 2022.

Enigma Innovations Group Limited (registered number 10940006) (“us”, “our”, “we”, “Adzy”) is the controller of your personal data collected through https://adzy.co and associated sub domains (the “Website”).  Adzy is committed to protecting and respecting your privacy.

This privacy policy (the “Policy” or “Privacy Policy”) sets out the types of personal data we collect and use when you access and visit the Website and how we may use that data.

1. Introduction
This Privacy Policy explains who we are, why and how we process personal data collected through your use of the Website and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to.

When you supply any personal data to us, we have legal obligations towards you in the way we use that data. For ease of reading, we have divided this Policy into several sections:

1.Introduction
2. What information can we collect?
3. Special Category Data
4. How is your personal information collected?
5. How and why do we use and share your personal information?
6. For how long do we keep your personal information?
7. Security
8. International Data Transfers
9. Your Rights
10. Contact Details

It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Website at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data.

This Policy supplements other notices on the Website and is not intended to override or replace them.

By visiting or otherwise using the Website, you agree to its terms (including as amended from time to time) and this Privacy Policy.  If, for any reason, you do not agree to the terms of this Policy, please stop using this Website.

We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law.  Where these changes are significant we will endeavour to let users of the Website know. However, it is your responsibility to check this Policy before each use of the Website – for ease of reference the top of this Policy indicates the date on which it was last updated.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Please note that the Website is not directed at children under the age of 18 (each a “Child” or “Children“) and we do not knowingly collect personal data about Children. If you believe we have collected personal data about your Child, you may contact us at privacy@adzy.co and request that we cease processing data about your Child.

2. What information can we collect?

What is personal data?

Where this Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.

By law, all organisations who process your personal data in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Privacy Policy.

What types of data we collect from you when you use the Website

The personal data we collect from you may include:

• Identity Data which includes your name, date of birth and gender.
• Contact Data which includes your e-mail address, billing address and delivery address.
• Financial Data which includes your bank account and payment card details.
• Transaction Data which includes details about payments to and from you and other details or services you have purchased from us.
• Licence Data which includes details about licences you have provided us and that we have sub-licenced to others.
• Technical Data which includes your IP address, your login data and browser type and version.
• Profile Data which includes your username and password, your interests, preferences, our analysis of your requirements, feedback and survey responses.
• Usage Data which includes information about how you use the Website.
• Marketing and Communications Data which includes your preferences in receiving marketing from us and our associated third parties.

3. Special Category Data

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

4. How is your personal information collected?

Direct interactions

When you use the Website to register as a member, complete a form, contact us by email or by post, request marketing be sent to you, provide financial details, order a product or service, participate in social media functions, take part in an online survey, browse from page to page, we may collect, store and use the personal data that you disclose to us.

Automated technologies or interactions

We shall also collect information about you when you visit and interact with the Website through the use of technologies such as cookies and machine learning. The following are examples of information we may collect:

• information about your device, browser or operating system;
• your IP address;
• information about links that you click and pages you view on the Website;
• length of visits to certain pages;
• subjects you viewed or searched for;
• page response times;
• records of download errors and/or broken links;
• page interaction information (such as details of your scrolling, clicks, and mouse-overs);
• types of images browsed;
• types of copy reviewed and edited;
• methods used to browse away from the page; and
• the full Uniform Resource Locators (URL) clickstream to, through and from this Website (including date and time).

We use the data described above for several different reasons. First we use it to ensure that the Website works properly and that you are able to receive the full benefit of it. Secondly, we use the data to monitor online traffic and audience participation across the Website. Thirdly, we use the data to gain insights about user preferences and interests. Fourthly, we use this data to provide you with a higher quality service. We undertake these activities because we have a legitimate interest in doing so.

For more information on cookies, please see our Cookies Policy at https://adzy.co/cookie-policy/

Third parties or publicly available sources

We also partner with third parties who may collect personal data including usage or statistical data through your use of the Website (including, for example, business partners, sub-contractors in technical support and delivery of services, advertising networks, analytics providers, search information providers, credit reference agencies).

Updating your information

If you want to update the information you have previously given to us, you can use the tools on the Website.

5. How and why do we use/share your personal data?

Lawful basis for processing your information

We will only use your personal data when the law allows us to.  Most commonly we will use your personal data in the following circumstances:

• Where you have asked us to do so, or consented to us doing so (although consent is not necessarily required for us to process your personal data);
• Where we need to do so in order to perform a contract we have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
• Where we need to comply with a legal or regulatory obligation.

Here are some examples about how we may use the information we collect about you and the lawful basis we rely on to do so.

Marketing and Communications

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you.  This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting Out of Marketing

To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email. You may also contact us or the third party directly if you do not wish to receive any marketing materials from us or them.

Sharing your personal data

Depending on how and why you provide us with your personal data we may share it in the following ways:

• we may share your personal data with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
• with selected third parties to which we sub-contract to provide various services and/or aspects of the Website’s functionality, such as where third party plugins provide functionality such as image hosting services (see “Service Providers” below); and
• with analytics and search engine providers that assist us in the improvement and optimisation of this Website as described above.

We may also disclose your personal data to third parties in the following events:

• if we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that transaction;
• if Enigma Innovations Group Limited or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers and contacts 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, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or
• in order to enforce or apply the Website’s terms of use or Adzy Terms of Service for Content Providers or Adzy Terms of Service for Customers; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Service Providers (Data Processors)

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and have verified with all of our data processors that they are GDPR compliant and that they clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. We do not allow our third-party service providers to use your personal data for their own purposes. The following is a list of our major service providers:

• AWS
• Namecheap
• Cloudflare
• Make.com
• Sendgrid/Twillio
• Airtable
• MongDB

Links to third party sites

Where we provide links to third party websites, plug-ins and applications that are not affiliated with www.adzy.co such sites are out of our control and are not covered by this Policy. If you access third party sites using the links provided, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies.  Please check these policies before you submit any personal data to those websites.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the associated website may become inaccessible or not function properly. For more information about the cookies we use, please see https://adzy.co/cookie-policy/

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. For how long do we keep your personal data?

We will hold your personal information on our systems only for as long as required to provide you with the services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.  We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for compliance purposes. In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information, although this may not always be possible if we are obliged to retain the data for compliance purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature.

7. Security

Adzy takes the protection of your information very seriously. We have put in place technologically and organisationally appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Where we have given you a password that enables you to access certain parts of the Website, you are responsible for keeping this password confidential.  We ask you not to share a password with anyone.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. International Data Transfers

Please note that some of our service providers may be based outside of the UK.  These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your request for information and the provision of services or support services.

Where we transfer your data to a service provider, we seek to ensure that appropriate safeguards are in place to make sure that personal data is held securely and that data subject rights are upheld.  Where we use certain service providers, we may use either specific contractual clauses mandated by regulators or require additional safeguards to be in place in order to give personal data greater protections. Such contractual clauses and/or additional safeguards shall be approved by the UK and EU regulators as compliant with the UK and EU GDPR regulations, respectively.

By submitting your personal information, you agree to this transfer, storing or processing. If you would like more information about how the mechanism via which your personal data is transferred, please contact privacy@adzy.co

9. Your Rights

You may have the following privacy rights:

If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us at privacy@adzy.co

In addition, if you are a resident of the EEA or the United Kingdom, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects.

Users of our Website have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the marketing communications we send you.

You can manage your cookie preferences by visiting our Cookie Consent Manager.

If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local supervisory authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

10. Contact Details

If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us by emailing at privacy@adzy.co

You may also lodge a complaint to the supervisory authority about the way we process your personal data.  We would however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us in the first instance.