Cookie and Privacy Policy - Eagle Point Partners

Cookie and Privacy Policy

This website (the “Site”) is owned and operated by Corbett Quilty Limited trading as Eagle Point Partners (“Eagle Point Partners”), located at no. 1 Maritana Gate, Canada Street, Waterford, Dublin 4. We understand that you care about your privacy, and so do we. To ensure you have a great experience using our Site we collect some information about you, and use cookies on www.eaglepoint.partners. This Privacy and Cookie Notice (the “Notice”) is to tell you how we collect your information on the Site and what we use that information for.

Any Personal Data which is processed by us in connection with your use of the site will be treated in accordance with Data Protection Law.

By using the Site, you are accepting the terms of this Notice.

Data Protection Terms Used in this Notice

“Data Protection Law” means the provisions of applicable data protection law including the Irish Data Protection Acts 1988 to 2018 and the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016)

“Personal Data” is any information that can be used to identify you, such as your name, email address, postal address or phone number.

“Data Controller” means any persons who determine the purpose for which and the manner in which any Personal Data is Processed.  Such persons have a responsibility to establish practices and policies in line with Data Protection Law.

“Data Processor” means any persons who Process Personal Data on behalf of a Data Controller.

“Processing” or “Processed” is any activity that involves the use of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Privacy and your Personal Data

What information do we collect and how do we use it?

When you use the Site, we may collect and Process the following Personal Data about you:

  • Information that you provide us by completing forms on our Site such as our newsletter sign-up and demo scheduling forms. This includes contact details such as your name, email address, job title and phone number. We collect this information with your consent, which you are free to withdraw at any time by (i) using the unsubscribe link in our emails, or (ii) emailing us at privacy@eaglepoint.partners.
  • Information that you upload to, or share through, our Site by using our services including profile information or any personal information in data that you upload.
  • If you contact us for customer or technical support, we may keep a record of that correspondence or conversation. We will Process this data in order to meet our contractual obligations towards you.
  • Information we receive from third party search engines such as Google, Yahoo and Microsoft (Bing and MSN) relating to your search queries that brought you to our site. We Process this data for our own legitimate interests (for example, in order to understand where customers or potential customer are coming from).

We use cookies to obtain details of your visits to our Site including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access. See our section on cookies below for further information.

Web analytics & activity logging

  • We use a web analytics tool (Google Analytics) to analyse Site usage, how our users arrive at our site, what they do on the site, what browser they are using and on what operating system etc.
  • We use an activity logging and customer service software (Intercom.io) in the platform so we can determine where errors happen when using the software, and can help give you a better, more personalised experience.

Use of Your Information

We will only process the Personal Data we collect about you if there is a reason for doing so, and if that reason is permitted under Data Protection Law. We will have a lawful basis for processing your Personal Data if we need to process your information in order to provide you with the service you have requested or to enter into a contract; we have your consent; we have a justifiable reason for processing your data; or we are under a legal obligation to do so.

Where we need to in order to provide you with the service you have requested or to enter into a contract, we use your Personal Data:

  • to enable us to provide you with access to the relevant parts of the Site;
  • to supply the services you have requested; and
  • to contact you where necessary concerning our services, such as to resolve issues you may have with your order.

We also process your Personal Data where we have a justifiable reason for doing so— for example personalisation of our service. We have listed these reasons below:

  • to improve the effectiveness and quality of service that our customers can expect from us in the future;
  • to enable our customer support team to help you with any enquiries or complaints in the most efficient way possible;
  • to contact you for your views and feedback on our services and to notify you if there are any important changes or developments to the Site or our services;
  • to analyse your activity on the Site so that we can administer, support, improve and develop our business and for statistical and analytical purposes and to help us to prevent fraud;
  • to enforce our contractual terms with you and any other agreement, and for the exercise or defence of legal claims and to protect the rights of Eagle Point Partners or others (including to prevent fraud); and
  • if you submit comments and feedback regarding the Site and the services, we may use such comments and feedback on the Site and in any marketing or advertising materials.

We will also analyse data about your use of our services from your location data to create profiles relating to you and for you. This means that we may make certain assumptions about what you may be interested in and use this, for example, to send you more communications, or to let you know about special offers or products which we think you may be interested in. This activity is referred to as profiling. You have certain rights in relation to this type of processing. Please see ‘Your Rights’ section below for more information.

Where we rely on legitimate interest as a basis for processing your Personal Data, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests.

Who do we share your information with?

The information we collect about you will be transferred to and stored on our servers located within the EU. We are very careful and transparent about who else your Personal Data is shared with.

We have a number of Data Processors who Process Personal Data on our behalf. For example, we use Amazon Web Services, Google Analytics, Intercom, Pipedrive, Wistia and Mailchimp to support aspects of the functionality of this Site.  Where we use a Data Processor, we will only do so pursuant to a written agreement which ensures that the privacy rights of data subjects are respected.

Sharing your information internally. We share your information with other Eagle Point Partners/Eagle Point group companies only where necessary for the purposes set out elsewhere in this policy.

Sharing your information with third parties. In addition to the Data Processors set out above, we share your information with third party service providers. The types of third party service providers whom we share your information with includes:

  • Payment providers (including online payment providers and fraud detection providers): for the purposes of providing services to us, for example when they process information such as credit card payments for us, provide support services to you or carry out fraud checks for us;
  • IT service providers (including cloud providers): for the purposes of data storage and analysis; and
  • Customer support partners: who will help us to resolve any issues you may have with our services.

We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this privacy policy when it is transferred to third parties.If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.

 

We may also share your Personal Data:

  • if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation or regulatory requirement. This includes exchanging information with other companies and other organisations for the purposes of fraud protection and prevention
  • in order to enforce our contractual terms with you and any other agreement;
  • to protect the rights of Eagle Point Partners, including to prevent fraud; and
  • with such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police.

International transfers of data

In some cases the personal data we collect from you might be processed outside the European Economic Area (“EEA”), such as the United States. These countries may not have the same protections for your personal data as the EEA has. However, we are obliged to ensure that the personal data that is processed by us and our suppliers outside of the EEA is protected in the same ways as it would be if it was processed within the EEA. There are therefore certain safeguards in place when your data is processed outside of the EEA.

We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • your personal data is transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • we use the EU approved Standard Contractual Clauses; and/or
  • where your personal data is transferred to third party providers based in the US, data may be transferred to them if they have self-certified under the Privacy Shield framework in relation to the type of data being transferred, which requires them to provide similar protection to personal data shared between the EU and the US.

Please contact us using the contact details at the bottom of this document. If you want further information on the countries to which personal data may be transferred and the specific mechanism used by us when transferring your personal data out of the EEA.

How long do we keep your information?

In line with the data minimization principles in the GDPR, we generally try to avoid holding Personal Data for longer than is necessary (having regard to the purposes for which it was collected).  If you are a customer, we will hold your Personal Data while you are a customer of ours. We may retain it after you have ceased to be a customer if required to fulfill a legal or regulatory requirement.

If you are not a customer, we will hold your personal data for no longer than 36 months.

Our retention periods may be adjusted from time to time. When determining the retention periods, we will take into account factors including:

  • our contractual obligations and rights in relation to the information involved;
  • legal obligation(s) under applicable law to retain data for a certain period of time;
  • statute of limitations under applicable law(s);
  • our legitimate interests where we have carried out balancing tests
  • (potential) disputes; and
  • guidelines issued by relevant data protection authorities.

Security

We adopt robust technologies and policies to ensure the Personal Data we hold about you is suitably protected. We take steps to protect your Personal Data from unauthorised access and against unlawful processing, accidental loss, destruction and damage. Where you have chosen a password that allows you to access certain parts of the Site, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.  Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your Personal Data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your Rights

Under Data Protection Law, you may have a number of rights concerning the Personal Data we hold about you. If you wish to exercise any of these rights, please contact us using the contact details set out at the bottom of this document. For additional information on your rights please contact your data protection authority and see below.

The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this policy.

The right of access. You have the right to obtain access to your information (if we’re Processing it). This will enable you, for example, to check that we’re using your information in accordance with data protection law. If you wish to access the information we hold about you in this way, please get in touch.

The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold by contacting us.

The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of certain of the information that we hold about you by contacting us.

The right to restrict Processing. You have rights to ‘block’ or ‘suppress’ further use of your information. When Processing is restricted, we can still store your information, but will not use it further.

The right to data portability. You have the right to obtain your personal information in an accessible and transferrable format so that you can re-use it for your own purposes across different service providers. This is not a general right however and there are exceptions. To learn more please get in touch.

The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or Process your information with the Office of the Data Protection Commissioner.

The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. we rely on consent as a legal basis for Processing your information), you have the right to withdraw that consent at any time. You can do this by contacting us.  Withdrawing consent will not however make unlawful our use of your information while consent had been in place.

The right to object to Processing. You have the right to object to certain types of Processing, including Processing for direct marketing and profiling. You can object by disabling cookies in your browser settings.

The rights set out above are not absolute – certain conditions may apply (e.g. there are statutory exemptions to your right to access your Personal Data held by Eagle Point Partners). However, Eagle Point Partners will do its best to vindicate your data protection rights to the greatest extent practically possible.

If you have any queries in relation to your Personal Data rights, you should contact us via privacy@eaglepoint.partners.

Making a Complaint

If you have any queries in relation to your Personal Data rights, you should contact us via privacy@eaglepoint.partners.

You also have the right to lodge a complaint with a supervisory authority in relation to the Processing of your Personal Data by Eagle Point Partners.  This supervisory authority can be in the place of your habitual residence (i.e. where you live), your place of work or the place of an alleged infringement of the provisions of the Data Protection Laws.

The Irish supervisory authority is the Office of the Data Protection Commissioner, and its details are available here.

Cookies and Tracking Technologies

We use a number of different cookies on our site. Cookies are small text files stored on a user’s computer by their web browser, designed to store basic information. For more information on cookies, please visit www.allaboutcookies.org.

We use the following cookies:

1: Session Cookies

Webpages have no memories, thus a user going from page to page will be treated as a complete new visitor. We use a session cookie to remember what information you have already provided to the website so you don’t get asked for the same information again. We also use a session cookie to remember your state (logged in or not logged in) on Eaglepoint.Partners so you don’t have to re-authenticate every time you click on a new page.  Our session cookies normally expire and the end of the browser session, or at midnight. However this may be over-ridden by your own browser settings, which you can adjust.

More information on session cookies and what they are used for can be found at www.allaboutcookies.org.

2: Third Party / Persistent Cookies for Site Analytics and Performance

We also use persistent cookies set by Google Analytics to analyse website usage, how our users arrive at our site, what they do on the site, what browser they are using and on what operating system etc., so we can improve the user experience.

You can find out more about Google’s position on privacy as regards its analytics service here.

Can I opt out of cookies?

We operate an implied consent policy which means that we assume you are happy with this usage. If you are not happy with this usage, then please don’t use Eagle Point Partners’s website or services.

The links below explain how you can control cookies via your browser:

Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.

Please be aware that restricting cookies may have a detrimental effect on your user experience at Eagle Point Partners.

Fingerprint IDs

We use device and browser fingerprinting to generate a unique Fingerprint ID for visitors to our site. Device and browser fingerprinting uses information such as device screen resolution, timezone and browser version to assign a unique ID to a visitor.  We use this information to help us more effectively measure the performance of different marketing channels.

You can find more information about this open-source technology here, and about Eagle Point Partners’s use of fingerprinting technology here.

Please note that device and browser fingerprinting cannot and does not tell us anything about what our visitors do beyond www.Eagle Point Partners.com.

Fingerprint IDs and Your Personal Data

Fingerprint IDs do not, on their own, identify a person. However, combined with other data (eg. CRM data), it is possible to link a Fingerprint ID to an individual, and thus, Fingerprint IDs may constitute Personal Data in certain circumstances. We rely on the legitimate interests of Eagle Point Partners in order to process this data.

The GDPR offers six lawful bases for the processing of Personal Data, one of which is the legitimate interests of Eagle Point Partners. The Data Protection Network has produced a guidance paper on the use of legitimate interests as a lawful basis for processing, and outlines a Legitimate Interests Assessment (LIA) for companies to use:

https://dma.org.uk/uploads/misc/59ca0f2e17ef3-dpn-li-guidance-publication_59ca0f2e17e5a.pdf

The UK Information Commissioner’s Office has expressed support for this approach. We have used this test as our basis for device and browser fingerprinting. If you wish to object to our use of Legitimate Interest as a method of collection in this case, please email privacy@eaglepoint.partners

Email Tracking

Emails we send you include tracking whether the user has opened and clicked on the email and what traffic the email sends to our Site.  If you want to be sure that your email activity is not tracked, then you should unsubscribe from Eagle Point Partner’s emails using the link contained in our emails.

Changes to this Policy

Any changes to our privacy policy will be posted to the Site and, where appropriate, we will notify you of the changes for example by email or push notification.  This privacy policy was last updated: 22 May 2018.

Links

Our Site contains links to and from third party websites.  These websites are not operated or maintained by Eagle Point Partners and Eagle Point Partners does not share your Personal Data with such websites.  If you follow a link to any of these websites please note that Eagle Point Partners does not accept any responsibility or liability for the privacy practices of such third parties websites.

Once you have left our Site you should consult the relevant privacy statement / policy of the third party website in order to determine what information (which may include Personal Data) it collects about you and how it is used.

How to Contact Us

If you have any queries about this Notice or your Personal Data, you can email us at privacy@eaglepoint.partners or write to us at Eagle Point Partners, Block 9 & 10, Belfield Office Park, Clonskeagh, Dublin 4.

 

Eagle Point Partners