Last updated: May 2019
Why does this policy exist?
We at Easternada are committed to protecting and respecting your privacy.
This policy (together with our terms and conditions, and any other policies referred to herein or therein) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
What does this Policy tell me about?
- Your Rights in regard to personal data
- What personal data we process
- How we use your data and the legal basis for this use
- When we share your personal data
- How long we store your data for
- Where we store your personal data
- Data Security
- Links to third-party websites
- Additional privacy protection for children using the internet
- Governing Law
2. Your rights in regard to your personal data
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, clicking the unsubscribe button on any email communication, managing this in your online account or by contacting us.
Where you have consented to us using your personal data, you can withdraw that consent at any time.
If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to amend it.
You also have the right to ask us to provide a copy of any personal data we hold about you.
Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format.
If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is processed.
To get in touch with us please email firstname.lastname@example.org
3. What personal data we process
We collect and process personal data about you when you interact with us and our services and when you purchase goods and services from us. The personal data we process includes:
- your name;
- your username and password;
- your shipping/billing address, email address and/or phone number;
- your bank details, including account number and sort code;
- the outcome of applications for financing;
- recordings of calls with our customer service team;
- history of live chat sessions with our customer service team;
- information related to the internet browser and device you use to access our services;
- the pages visited and individual interactions with our services;
- and/or any other information you provide
4. How we use this data and the legal basis for this use
We process the personal data above for the following purposes:
- to fulfill any order or contract, for example, if you make a purchase from us or enter into an agreement to receive services. This may include verifying your identity, taking payments, communicating with you, providing customer services and arranging the delivery or other provision of products or services. We require this information in order to enter into a contract with you and are unable to do so without it;
Easternada do not hold any payment card data;
- to comply with our legal obligations;
- with your consent to respond to any requests in relation to your data and per your legal rights and/or in accordance with our legitimate interests including to investigate any requests received from you or from others, about our website or services;
- we may use information you provide to personalize (i) our communications to you; (ii) our website; and (iii) products or services for you, in accordance with our legitimate interests;
- to monitor use of our websites and online services. We may use your information to help us check, improve and protect our products, content, services and websites, in accordance with our legitimate interests;
- in circumstances where you contact us by live chat, transcripts will be stored for quality, training and security purposes, in accordance with our legitimate interests;
- in circumstances where you contact us by email, transcripts will be stored for quality, training and security purposes, in accordance with our legitimate interests;
- in circumstances where you contact us by telephone, calls may be recorded for quality, training and security purposes, in accordance with our legitimate interests; and
- to market to you using third-party dynamic re-targeting;
- we may use your data to invite you to take part in market research or surveys.
We may also market to you in relation to relevant products and services, this will only be sent where you have consented to receive it, you have been given an opportunity to opt-out. You will continue to be able to opt-out of electronic direct marketing at any time by following the instructions in the relevant communication.
5. When we share your personal data
We may share your personal data with our subsidiaries to process it for the purposes of inter-group administration and to deliver products or services where elements of these are provided by group companies other than those with which you have directly contracted.
We may also share your personal data with the below third parties:
- our professional advisers, external legal advisers and financial advisers;
- marketing and communications agencies where they have agreed to process your personal data in line with this Privacy Notice;
- market research companies;
- our suppliers, business partners and sub-contractors; and/or
- search engine and web analytics.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws. Personal data may also be shared with third party service providers who will process it on behalf of Easternada for the purposes above. Such third parties include, but are not limited to, providers of website hosting, security, finance applications, logistics partners and payment providers.
In the event that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.
6. How long we store your data for
We will not keep your personal information for any purpose for longer than is strictly necessary and will only retain the personal information that is necessary in relation to the purpose. We are also required to retain certain information as required by law or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse pursuant to our terms and conditions.
We will retain your data for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place. In some instances, laws may require Easternada to hold certain information for specific periods other than those listed above.
7. Where we store your personal data
Primarily we store all of our data within the European Economic Area (“EEA”) however the personal data that we collect from you may be transferred to, and stored outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, in which case the third country's data protection laws will have been approved as adequate by the European Commission or other applicable safeguards are in place.
8. Data Security
Cookies help us to improve the Services and to deliver a better and more personalized service. They enable us to:
- estimate our audience size and usage pattern;
- store information about your preferences, and so allow us to customize the Services according to your individual interests;
- speed up your searches;
- recognize you when you return to any website or application;
Provide anonymity statistical information: Non-personal data may be gathered on our behalf using cookies, log file data, and code that is embedded on our websites by specific third-party partners to help these selected third parties to deliver relevant advertisements to you.
We use this non-personal information to help improve the services we provide to you. When you visit the publicly available sections of the Services, a session ID cookie is placed on your computer that only lasts while you’re visiting. We also place persistent cookies (also known as local storage devices) on members’ computers, so that we remember them to make your login in process faster and easier.
Controlling and deleting cookies
- by using the opt-outs provided below;
- by visiting http://www.youronlinechoices.com/; or
- Through your browser, as explained below.
You can also block cookies by changing your browser settings so that cookies from this Site cannot be placed on your computer or mobile device. In order to do this follow the instructions provided by your browser (usually located within the "Help", "Tools" or "Edit" facility). Disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser. Further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.aboutcookies.org and www.youronlinechoices.eu.
What cookies are used for and why we use them on this Site
This table shows fully the cookie functions and why they are used, although our uses may change over time and it is important that you revisit this page to understand these uses:
Analytics and research
We use the information collected by analytical tools to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
These cookies help us to identify our members so that when you’re logged in, you can enjoy all of the features without having to continually log in – our website “remembers” you and allows you full access without the need to keep entering your log in details.
We need to use certain cookies and local storage devices to ensure our members have the best possible experience, such assisting with your navigation of our site, ensuring pages load up quickly and respond faster to your requests for our Services.
Ad Serving & Behavioral Advertising
We may sell space on some of our websites to advertisers. We use several services to help us and advertisers understand what adverts you might be interested in. These cookies hold information about the computer - they don't hold personal information about you (ie it's not linked to you as an individual). But they might hold a record of what other websites you've looked at - so we could show you a car advert if you've previously visited a motoring website.
Advertisements on this Site and the other sites you visit are provided by other organisations. Our advertising partners will serve advertisements that they believe are most likely to be of interest to you, based on information about your visit to the Site and other websites. In order to do this, our advertising partner may need to place a cookie on your computer. For more information about this type of online behavioral advertising, about cookies, and about how to turn this feature off, please visit www.youronlinechoices.eu and select your country. Please note that turning off advertising cookies won't mean that you are not served any advertising merely that it will not be tailored to your interests.
10. Links to third-party websites
Our websites, apps, and promotional materials, may, from time to time, contain links to and from the websites of our third-party networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
11. Additional privacy protection for children using the internet
We do not solicit or target persons younger than legal age for collection of information online. Our Site does not permit children under the age of 18 to become users and we do not accept any information from children. By submitting information to us you represent that you are over the age of 18. We encourage minors to seek the consent of their parents before providing any information about themselves or their households to anyone on the Internet. We encourage parents to take an active role to protect the privacy and security of their children and to prevent the inappropriate use of information about their children. We support the development of technologies that help parents to control the collection and use of personal information from children who use online services in their households.
12. Governing Law