Privacy Policy

We (Easy Marketing Ltd) (doing business as Easy Marketing) (“Easy Marketing,” “EM”, “we,” “us,” or “our”) believe that protecting the security and privacy of your personal data is important. Therefore, this Privacy Notice explains how we collect, store, use, disclose and transfer (hereinafter “process”) your personal data when you use our services (“Services”), such as when you:

  • Visit our website at www.easymarketing.ukor any website of ours that links to this privacy notice.
  • Engage with us in other related ways, including any sales, marketing, or events

The personal data we collect about you depends on the context of your interactions with us and the products. Services and features that you use, your location, and applicable law.

This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: https://easymarketing.uk/terms-and-conditions/ and our Cookie Policy, which can be found at https://easymarketing.uk/cookie-policy

www.easymarketing.uk(the “Site”) is owned and operated by Easy Marketing Ltd.

Information of Easy Marketing Ltd

Nature of business (SIC): 73110 – Advertising agencies

Company number 14020630

Registered office address: Covent Garden, 71-75 Shelton Street, London, United Kingdom, WC2H 9JQ

 

Easy Marketing is the data controller and can be contacted at:

UK and other countries: Alice Sheng

Email: informationofficer@easymarketing.uk

Contact: +44 07360058886

Address: Covent Garden, 71-75 Shelton Street, London, United Kingdom, WC2H 9JQ

 

China: Leo Wei

Email: leowei@easymarketing.uk

Contact: +86 15527729050

Address: Room 02, 3rd Floor, Building 5, Wuhan International Center, No. 1, Guanshan 2nd Road, Donghu New Technology Development Zone, Wuhan, China.

2.1 How We Process Personal Data?

We collect and process the following data about you:

  • Information you give us: This is information about you that you give us by filling in forms on our Site or by corresponding with us by email or otherwise. It includes any communication you send to us, whether through contact or opt-in forms on our website, through email, text, social media messaging, social media posting or any other communication you send us. The information you give us may include your name, address, email address, age, location and financial information in case of a purchase or recruitment. Please let us know if any of this information changes so we can keep our records up to date.
  • Information we collect from your use of our Site: About each of your visits to our Site, we will automatically collect the following information:
  • Technical information, such as the Internet protocol (IP) address used to connect your device to the Internet.
  • The location where you connected to our Service
  • Your internet service provider (ISP).
  • What type of device are you using to access our Service?
  • Other online services information such as your login activity data, details about your browser and length of visit to pages on our website, page views and website navigation paths, details about the number of times you have used our website, your time zone settings and other information about the devices you use to access our website. The source of this data is our analytics tracking system.
  • Information we collect throughout our relationship with you: This is information relating to products (free or paid) that you download or purchase from us.
  • Marketing Information: This includes data about your preferences in receiving marketing from our third parties and us and your communication preferences.
  • Note: We may use information you give us, the information we collect from your use of our Site, the information we collect throughout our relationship with you, and marketing information to:
  • Deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements);
  • Measure or understand the effectiveness of the advertising we serve you

Our lawful ground for processing this information is our legitimate interests which are to provide our Service to you.

This Service includes but is not limited to: electronics products we sell on this website, the articles, podcasts and videos you find on this website, downloadable media (such as PDFs), and any other materials delivered over email, all of which we gladly offer free of charge and invest significant funds in developing.

Additionally, we have a legitimate interest in using the data you provide us to inform you of products and services that are relevant, interesting and personal to you. This is done through occasional email marketing messages and generates revenue with which we fund our Service (outlined above). Each time we send you marketing materials (or any other email communication), we give you the option to unsubscribe.

2.2 Categories of Personal Data Processed.

When visiting our websites or using our applications, or online services (each an “Online Offering”), we process information which you have actively and voluntarily provided about yourself, or which has been generated by us in connection with your use of the Online Offerings, and includes the following categories of personal data:

 

2.2.1 Data Collected Automatically

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information). However, it may include device and usage information, such as your IP address, browser, device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

  • Log and Usage Data. Log and usage data are service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other devices you use to access the Services. Depending on the device used, this data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
  • Location Data. We collect location data, such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt-out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of the Services.

The information we collect includes

  • IP address;
  • Location;
  • Clicked links;
  • Content viewed;
  • Bounce rate;
  • Phone type you are using
  • Language preference;
  • The browser you are using; and
  • Keywords you find to reach our website.

2.2.2 Data Collected in a Non-Automatic Way

We may also collect the following data when you perform certain functions on our Site.

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

  • First and last name;
  • Email address;
  • Phone number;
  • Payment information;
  • Business Details;
  • Job titles
  • Usernames
  • Passwords
  • Contact Preferences
  • Billing addresses
  • Debit/credit card numbers
  • Contact or authentication data
  • Your gender, age, country, education, career background, salary expectation and more for recruitment;
  • Information submitted as part of a support request, survey or comment or forum post; and
  • Further personal data that you provide by filling in forms in our Online Offerings.

This data may be collected using the Forms. You will receive a consent notice before we collect all your information.

2.2.3 Sensitive Information. 

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number) and the security code associated with your payment instrument. All payment data is stored by Easy Marketing Ltd

2.2.4 Social Media Login Data. 

We may allow you to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account.

In Short: We process your information to provide, improve, and administer our Services, communicate with you for security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent.

  • Information you give us or receive from other sources: We process this data for communication with you, record-keeping and administration, and the establishment, pursuance or defence of legal claims. Our lawful ground for processing this information is our legitimate interests, which in this case are to reply to communications sent to us by you, to keep accurate records and to establish, pursue or defend legal claims. We use this information:
    • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order;
    • To improve our Service to you, to ensure that content from our Site is presented ;

most effectively for you and your device;

  • To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services;
  • To send you marketing and promotional communications. We may process the personal information you send us for our marketing purposes if this is following your marketing preferences. You can opt-out of our marketing emails at any time.
  • To provide you with service communications so we can fulfil our obligations to you. These may be sent by email. These will include notifications about changes to our Service, event details and information about products that you have signed up for;To provide you with marketing communications including, with your permission, information about other goods and services we offer that are similar to those that you have already purchased or enquired about; or
  • In our or a third party’s legitimate interests of keeping customers up to date with goods and services, we are increasing awareness of ourselves and third parties within the market, making promotional offers and generating new business, and building and maintaining loyalty or market share.

Information we collect from your use of the Site: We process this data to analyze your use of our website and other online services, to administer and protect our business and website and to deliver relevant and engaging website content and advertisements to you, as well as to understand the effectiveness of our advertising and marketing strategies. Our lawful ground for processing this information is our legitimate interests, which in this case are to properly administer our website and our business, grow our business, and make decisions about our marketing strategies. We use this information for the following purposes:

  • To administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • To improve our Site to ensure that content is presented most effectively for you and your device;
  • To identify usage trends. We may process information about how you use our Services to understand better how they are being used so we can improve them.

As part of our efforts to keep our Site safe and secure;

  • To measure or understand the effectiveness of advertising we serve to you and others and to deliver relevant advertising to you.

Information we collect throughout our relationship. We process this data to supply the goods and/or services you have purchased from us or our affiliates and to keep records of such transactions. Our lawful ground for processing this data is the fulfilment of a contract between you and us and/or taking steps to enter into such a contract at your request.

Marketing Information: We process this data to enable you to participate in our promotions, competitions, prize draws and free giveaways, as well as to deliver relevant website content and advertisements to you and measure or understand the effectiveness of these advertising and marketing strategies. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services and website, to develop them, grow our business and make decisions about our marketing strategies.

We may use your personal data and other information as described above for the following purposes:

  • to understand your interests and preferences concerning the Easy Marketing Digital Channels;
  • to register an account, grant you access to and authenticate you on Easy Marketing’s Digital Channels;
  • to monitor access to Digital Channels or downloads;
  • to subscribe and in the course of the subscription, follow comments, posts, articles, authors, webinars, news and updates about Easy Marketing products and services;
  • in the course of the creation of and publishing media and press releases, to create brochures, news, media assets (such as images, videos), newsletters etc.;
  • in order to create articles that will be published on Easy Marketing’s internal and external Digital Channels;
  • to provide you with the possibility to create your profile on Easy Marketing Digital Channels for example to create posts, make comments, follow posts and discussions and sign-up for newsletters etc.;
  • to allow you to make posts, and comments, upload content, participate in quizzes and publish opinions on Easy Marketing Digital Channels;
  • in the course of sharing job adds on Easy Marketing’s Digital Channels;
  • to provide customer support and process, evaluate and respond to requests and inquiries;
  • to collect your image and your personal data in the course of an event to show impressions of an event;
  • to register and organize webinars.

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

 

This section applies to you if you are in the EU or UK.

For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the “GDPR”). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018 and UK GDPR.

Easy Marketing has not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR. We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

Easy Marketing relies on the following legal basis to collect and process the personal data of users in the EU:

Processing of user personal data is necessary for us to take, at the request of a user, steps before entering a contract or for the performance of a contract to which a user is a party. If a user does not provide the personal data necessary to perform a contract, the consequences are as follows: You may not be able to conclude a payment.

If you are located in the US, this section applies to you.

Easy Marketing is committed to compliance with the California Consumer Privacy Act (“CCPA”).

The CCPA provides Consumers (California residents) with specific rights regarding their personal information. However, please note that the CCPA only provides California Resident employees and applicants with the right of notice regarding personal information collected and the business purpose. At the same time, business-to-business persons are only entitled to the Right to Opt-out.

This section describes those CCPA rights and explains how to exercise them.

  1. Right to Know About Personal Information Collected, Disclosed, or Sold

As a Consumer under the CCPA, you have the right to request from Easy Marketing the following data collected by Easy Marketing in the preceding 12 months:

categories of personal information that we have collected about you;

  • for each category of personal information, the categories of sources from which the personal information is collected;
  • for each category of personal information, the business or commercial purpose for collecting or selling personal information;
  • for each category of personal information, the categories of third parties with whom Easy Marketing shares such personal information; and
  • the specific pieces of personal information Easy Marketing have collected about you.

As a Consumer under the CCPA, you have the right to the above-listed information related to your Personal Information that Easy Marketing has collected, disclosed and/or sold in the preceding 12 months.

Easy Marketing will not collect and sell to third parties the personal information of a consumer with whom the business does not have a direct relationship.

  • Information you give us or receive from other sources: We process this data for communication with you, record-keeping and administration, and the establishment, pursuance or defence of legal claims. Our lawful ground for processing this information is our legitimate interests, which in this case are to reply to communications sent to us by you, to keep accurate records and to establish, pursue or defend legal claims. We use this information:
    • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order;
    • To improve our Service to you, to ensure that content from our Site is presented ;

most effectively for you and your device;

  • To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services;
  • To send you marketing and promotional communications. We may process the personal information you send us for our marketing purposes if this is following your marketing preferences. You can opt-out of our marketing emails at any time.
  • To provide you with service communications so we can fulfil our obligations to you. These may be sent by email. These will include notifications about changes to our Service, event details and information about products that you have signed up for;To provide you with marketing communications including, with your permission, information about other goods and services we offer that are similar to those that you have already purchased or enquired about; or
  • In our or a third party’s legitimate interests of keeping customers up to date with goods and services, we are increasing awareness of ourselves and third parties within the market, making promotional offers and generating new business, and building and maintaining loyalty or market share.

Information we collect from your use of the Site: We process this data to analyze your use of our website and other online services, to administer and protect our business and website and to deliver relevant and engaging website content and advertisements to you, as well as to understand the effectiveness of our advertising and marketing strategies. Our lawful ground for processing this information is our legitimate interests, which in this case are to properly administer our website and our business, grow our business, and make decisions about our marketing strategies. We use this information for the following purposes:

  • To administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • To improve our Site to ensure that content is presented most effectively for you and your device;
  • To identify usage trends. We may process information about how you use our Services to understand better how they are being used so we can improve them.

As part of our efforts to keep our Site safe and secure;

  • To measure or understand the effectiveness of advertising we serve to you and others and to deliver relevant advertising to you.

Information we collect throughout our relationship. We process this data to supply the goods and/or services you have purchased from us or our affiliates and to keep records of such transactions. Our lawful ground for processing this data is the fulfilment of a contract between you and us and/or taking steps to enter into such a contract at your request.

Marketing Information: We process this data to enable you to participate in our promotions, competitions, prize draws and free giveaways, as well as to deliver relevant website content and advertisements to you and measure or understand the effectiveness of these advertising and marketing strategies. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services and website, to develop them, grow our business and make decisions about our marketing strategies.

We may use your personal data and other information as described above for the following purposes:

  • to understand your interests and preferences concerning the Easy Marketing Digital Channels;
  • to register an account, grant you access to and authenticate you on Easy Marketing’s Digital Channels;
  • to monitor access to Digital Channels or downloads;
  • to subscribe and in the course of the subscription, follow comments, posts, articles, authors, webinars, news and updates about Easy Marketing products and services;
  • in the course of the creation of and publishing media and press releases, to create brochures, news, media assets (such as images, videos), newsletters etc.;
  • in order to create articles that will be published on Easy Marketing’s internal and external Digital Channels;
  • to provide you with the possibility to create your profile on Easy Marketing Digital Channels for example to create posts, make comments, follow posts and discussions and sign-up for newsletters etc.;
  • to allow you to make posts, and comments, upload content, participate in quizzes and publish opinions on Easy Marketing Digital Channels;
  • in the course of sharing job adds on Easy Marketing’s Digital Channels;
  • to provide customer support and process, evaluate and respond to requests and inquiries;
  • to collect your image and your personal data in the course of an event to show impressions of an event;
  • to register and organize webinars.

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of Easy Marketing to another company.
  • When we use Google Maps Platform APIs, we may share your information with specific Google Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy Policy.
  • We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • Business Partners. We may share your information with Easy Marketing’s business partners to offer you certain products, services, or promotions.
  • Employees:We may disclose user data to any member of our organization who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.
  • Other Disclosures

We will not sell or share your data with other third parties, except in the following cases:

  • If the law requires it;
  • If it is required for any legal proceeding;
  • To prove or protect our legal rights; and

If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a more extended retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information or, if this is impossible (for example, because your personal information has been stored in backup archives). We will securely store your personal information and isolate it from any further processing until deletion is possible.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. Therefore, you should only access the Services within a secure environment.

 

We do not knowingly collect or use personal data from children under 16. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 has provided us with personal data, their parent or guardian may contact our privacy officer. If you become aware of any data we may have collected from children under 18. Please contact us at informationofficer@easymarketing.uk

In some regions (like ), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to processing your personal information. We will consider and act upon any request following applicable data protection laws.

Suppose you are located in the EEA or UK, and you believe we are unlawfully processing your personal information. In that case, you also have the right to complain to your local data protection supervisory authority.

9.1 How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to whom we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our privacy officer here:

 

Contact Person:Alice Sheng

Email: informationofficer@easymarketing.uk

Contact: +44 07360058886

Address: Covent Garden, 71-75 Shelton Street, London, United Kingdom, WC2H 9JQ.

5.2               How to Opt-Out of Data Collection, Use or Disclosure

In addition to the method(s) described in the How to Access, Modify, Delete, or Challenge the Data Collected section, we provide the following specific opt-out methods for the forms of collection, use, or disclosure of your personal data specified below:

  • You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages or emails that we send;
  • Opt-out of the use of your personal data for marketing emails. You can opt-out by clicking “unsubscribe” at the bottom of any marketing email or updating your email preferences under “Your Account.”
  • Account Information. If you would like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account.
  • Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
  • Cookies and similar technologies: Most Web browsers accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you remove or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at informationofficer@easymarketing.uk.

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the contact information Easy Marketing provided.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To request the removal of such data, please contact us using the information provided below. Include the email address associated with your account and a statement that you reside in California. We will ensure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We will use the following categories of personal information:

Category Examples Collected

 

                 Purpose

Collected

Identifiers:

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Yes

Personal information categories are listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Yes

Protected classification characteristics under California or federal law

Age (40 years or older), race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Yes

Commercial information

Records of personal property, products or services purchased, obtained, considered, or other purchasing or consuming histories or tendencies.

Yes

 Internet or other similar network activity

Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement (“cookie” information).

Yes

 Biometric information.

Genetic, physiological, behavioural, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, thermal body scans, optical photo image, temperature readings, or exercise data.

No

Geolocation data

Physical location or movements.

No

Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

Yes

Professional or employment-related information

Current or past job history or performance evaluations and recorded video interviews.

Yes

Non-public education information (per the Family Educational Rights and Privacy Act (20 USC Section 1232g, 34 CFR Part 99))

Education records directly related to a student maintained by an educational institution or party acting on its behalfs, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Yes

Inferences are drawn from other personal information

The profile reflects a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

Yes

As a Consumer under the CCPA, you have the right to request from Easy Marketing all the data collected by Easy Marketing in the preceding 12 months.

This section applies and provides you with further information if the processing by one of our companies (i) occurs in Brazilian territory, (ii) concerns the data of individuals located in Brazilian territory, (iii) comprises personal data collected in Brazilian territory or (iv) has as its objective the offer or supply of goods or services to individuals located in Brazilian territory. In these cases, the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados – LGPD) applies to the processing of your data, and the following additions and/or deviations apply to sections 2, 5, 6, 9 of this Data Privacy Notice:

 

Retention Periods

 

As allowed under article 16 of LGPD, we may retain your personal data to comply with legal or regulatory obligations (such as retention obligations under tax or commercial laws), during the legal statute of the limitation period, or for the regular exercise of rights in judicial, administrative or arbitration proceedings.

 

Additionally to the rights mentioned in this Data Privacy Notice,   you are entitled under LGPD to:

  • In case you understand your data is not being processed per the applicable data protection law or in an excessive way, request us to anonymize, block or delete unnecessary or excessive personal data or;
  • Request information regarding the public and/or private entities we shared your personal data with;
  • Be informed about the possibility of not giving your consent to process your data and the consequences of not giving the consent in case we request your consent to process your data;
  • Revoke at any time your consent to our processing of your personal data in case we request your consent to process your data

Legal basis of the processing

The Brazilian General Data Protection Law requires us to provide you with information on the legal basis of processing your personal data.

The legal basis for our processing is:

  • Article 7 V LGPD (“Contract Performance”);
  • Article 7 II LGPD (“Compliance with Legal Obligations”);
  • Article 10 I and II LGPD (“Legitimate Interest”).
  • Article 7 I LGPD (“Consent”).

 

International transfers 

 

Following the LGPD requirements defined in Article 33 of the Brazilian General Data Protection Law, if we transfer your personal data outside the Brazilian territory, we ensure that your data is protected in a manner which is consistent with the Brazilian General Data Protection Law, we will follow the applicable law and decisions imposed by the proper authority.

 

Your competent data protection contact

 

If this section applies, you may also contact informationofficer@easymarketing.uk

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the contact information Easy Marketing provided.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To request the removal of such data, please contact us using the information provided below. Include the email address associated with your account and a statement that you reside in California. We will ensure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We will use the following categories of personal information:

Category Examples Collected

                 Purpose

Collected

Identifiers:

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Yes

Personal information categories are listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Yes

Protected classification characteristics under California or federal law

Age (40 years or older), race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Yes

Commercial information

Records of personal property, products or services purchased, obtained, considered, or other purchasing or consuming histories or tendencies.

Yes

 Internet or other similar network activity

Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement (“cookie” information).

Yes

 Biometric information.

Genetic, physiological, behavioural, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, thermal body scans, optical photo image, temperature readings, or exercise data.

No

Geolocation data

Physical location or movements.

No

Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

Yes

Professional or employment-related information

Current or past job history or performance evaluations and recorded video interviews.

Yes

Non-public education information (per the Family Educational Rights and Privacy Act (20 USC Section 1232g, 34 CFR Part 99))

Education records directly related to a student maintained by an educational institution or party acting on its behalfs, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Yes

Inferences are drawn from other personal information

The profile reflects a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

Yes

As a Consumer under the CCPA, you have the right to request from Easy Marketing all the data collected by Easy Marketing in the preceding 12 months.

This section applies and provides you with further information if your personal data is processed by one of our companies located in the European Economic Area.

 Data Controller

The specific company identified on this page as the website’s operator is the data controller in the General Data Protection Regulation for the processing activities described in this Privacy Notice.

 

We may share Business Partner contact information with affiliated Easy Marketing companies in our business relationship with you. Easy Marketing and our Business Partner are jointly responsible for properly protecting your personal data (Art. 26 General Data Protection Regulation).

To exercise your rights, you may reach out to: informationofficer@easymarketing.uk

 

Legal basis of the processing

The General Data Protection Regulation requires us to provide you with information on the legal basis of processing your personal data.

 The legal basis for our processing data about you is that such processing is necessary for

  • exercising our rights and performing our obligations under any contract we make with you (Article 6 (1) (b) General Data Protection Regulation) (“Contract Performance”);
  • Compliance with our legal obligations (Article 6 (1) (c) General Data Protection Regulation) (“Compliance with Legal Obligations”); and/or
  • Legitimate interests pursued by us (Article 6 (1) (f) General Data Protection Regulation) (“Legitimate Interest“). Generally, the legitimate interest we pursue concerning our use of your personal data is the efficient performance or management of (i) your use of the Online Offerings and/or (ii) our business relationship with you. Where the below table states that we rely on our legitimate interest for a given purpose, we believe that your interests and rights or freedoms do not override our legitimate interest, given (i) the regular reviews and related documentation of the processing activities described herein, (ii) the protection of your personal data by our data privacy processes, including our Binding Corporate Rules on the Protection of Personal Data, (iii) the transparency we provide on the processing activity, and (iv) the rights you have about the processing activity. If you wish to obtain further information on this balancing test approach, please contact our Data Privacy Organization at: informationofficer@easymarketing.uk

In some cases, we may ask if you consent to the appropriate use of your personal data. In such cases, the legal basis for our processing that data about you may (in addition or instead) be that you have consented (Article 6 (1) (a) General Data Protection Regulation) (“Consent”).

Processing of personal data in the context of Online Offerings – Purpose and Legal Basis

 

To provide the Online Offering’s services and functions, which include creating and administering your online account, updating, securing, troubleshooting, providing support, and improving and developing our Online Offerings.

  • Contract Performance (Article 6 (1) (b) General Data Protection Regulation)
  • Legitimate Interest (Article 6 (1) (f) GDPR)

To bill your use of the Online Offering

  • Contract Performance (Article 6 (1) (b) General Data Protection Regulation)
  • Legitimate Interest (Article 6 (1) (f) GDPR

To verify your identity

  • Contract Performance (Article 6 (1) (b) GDPR)
  • Legitimate Interest (Article 6 (1) (f) GDPR)

To answer and fulfil your requests or instructions

  • Contract Performance (Article 6 (1) (b) GDPR)
  • Legitimate Interest (Article 6 (1) (f) GDPR)

To process your order or to provide you with access to specific information or offers

  • Contract Performance (Article 6 (1) (b) GDPR)
  • Legitimate Interest (Article 6 (1) (f) GDPR)

To send you marketing information or to contact you in the context of customer satisfaction surveys, as further explained in Section 3

  • Consent, if voluntarily provided (Article 6 (1) (a) GDPR)
  • Legitimate Interest (Article 6 (1) (f) GDPR)

As reasonably necessary to enforce the Online Offering’s terms, establish or preserve a legal claim or defence, and prevent fraud or other illegal activities, including attacks on our information technology systems.

  • Compliance with Legal Obligations (Article 6 (1) (c) GDPR
  • Legitimate Interest (Article 6 (1) (f) GDPR)

 

Processing of personal data related to your business relationship with us – Purpose and Legal Basis

 

Communicating with Business Partners about our products, services and projects, e.g. by responding to inquiries or requests or providing you with technical information about purchased products

  • Contract Performance (Article 6 (1) (b) GDPR)
  • Legitimate Interest (Article 6 (1) (f) GDPR)

Planning, performing and managing the (contractual) relationship with Business Partners; e.g. by performing transactions and orders of products or services, processing payments, performing accounting, auditing, billing and collection activities, arranging shipments and deliveries, facilitating repairs and providing support services;

  • Contract Performance (Article 6 (1) (b) GDPR)
  • Compliance with Legal Obligations (Article 6 (1) (c) GDPR)

Administrating and performing market analysis, sweepstakes, contests, or other customer activities or events;

  • Consent, if voluntarily provided (Article 6 (1) (a) GDPR)
  • Legitimate Interest (Article 6 (1) (f) GDPR)

Conducting customer satisfaction surveys and direct marketing activities as further explained in Section 3; 

  • Consent, if voluntarily provided (Article 6 (1) (a) GDPR)
  • Legitimate Interest (Article 6 (1) (f) GDPR)

Maintaining and protecting the security of our products, services and websites, preventing and detecting security threats, fraud or other criminal or malicious activities;

  • Legitimate Interest (Article 6 (1) (f) GDPR)

Ensuring compliance with legal obligations (such as record keeping obligations), export control and customs, Business Partner compliance screening obligations (to prevent white-collar or money laundering crimes), and our policies or industry standards; and

  • Compliance with Legal Obligations (Article 6 (1) (c) GDPR)
  • Legitimate Interest (Article 6 (1) (f) GDPR)

Solving disputes, enforcing our contractual agreements and establishing, exercising or defending legal claims.

  • Compliance with Legal Obligations (Article 6 (1) (c) GDPR)
  • Legitimate Interest (Article 6 (1) (f) GDPR)

International data transfers

 

If we transfer your personal data outside the European Economic Area, we ensure that your data is protected in a manner consistent with the General Data Protection Regulation. Therefore, and if required by applicable law, we take the following measures:

  • We may share your data with affiliated companies outside the European Economic Area, but we will enter Binding Corporate Rules with these Business Partners.
  • We transfer personal data to external recipients outside the European Economic Area only if the recipient has (i) entered into EU Standard Contractual Clauseswith us or (ii) implemented Binding Corporate Rules in its organization. You may request further information about the safeguards implemented concerning specific transfers by contacting  informationofficer@easymarketing.uk

 

Your competent data protection authority

 

In case of data privacy-related concerns and requests, we encourage you to contact our Data Privacy Organization at informationofficer@easymarketing.uk. Besides contacting the Data Privacy Organization, you always have the right to approach the competent data protection authority with your request or complaint. 

Retention Periods

As allowed under article 16 of LGPD, we may retain your personal data to comply with legal or regulatory obligations (such as retention obligations under tax or commercial laws), during the legal statute of the limitation period, or for the regular exercise of rights in judicial, administrative or arbitration proceedings.

Additionally to the rights mentioned in this Data Privacy Notice,   you are entitled under LGPD to:

  • In case you understand your data is not being processed per the applicable data protection law or in an excessive way, request us to anonymize, block or delete unnecessary or excessive personal data or;
  • Request information regarding the public and/or private entities we shared your personal data with;
  • Be informed about the possibility of not giving your consent to process your data and the consequences of not giving the consent in case we request your consent to process your data;
  • Revoke at any time your consent to our processing of your personal data in case we request your consent to process your data

Legal basis of the processing

The Brazilian General Data Protection Law requires us to provide you with information on the legal basis of processing your personal data.

The legal basis for our processing is:

  • Article 7 V LGPD (“Contract Performance”);
  • Article 7 II LGPD (“Compliance with Legal Obligations”);
  • Article 10 I and II LGPD (“Legitimate Interest”).
  • Article 7 I LGPD (“Consent”).

International transfers 

Following the LGPD requirements defined in Article 33 of the Brazilian General Data Protection Law, if we transfer your personal data outside the Brazilian territory, we ensure that your data is protected in a manner which is consistent with the Brazilian General Data Protection Law, we will follow the applicable law and decisions imposed by the proper authority.

Your competent data protection contact

If this section applies, you may also contact informationofficer@easymarketing.uk

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the contact information Easy Marketing provided.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To request the removal of such data, please contact us using the information provided below. Include the email address associated with your account and a statement that you reside in California. We will ensure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We will use the following categories of personal information:

Category Examples Collected

                 Purpose

Collected

Identifiers:

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Yes

Personal information categories are listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Yes

Protected classification characteristics under California or federal law

Age (40 years or older), race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Yes

Commercial information

Records of personal property, products or services purchased, obtained, considered, or other purchasing or consuming histories or tendencies.

Yes

 Internet or other similar network activity

Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement (“cookie” information).

Yes

 Biometric information.

Genetic, physiological, behavioural, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, thermal body scans, optical photo image, temperature readings, or exercise data.

No

Geolocation data

Physical location or movements.

No

Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

Yes

Professional or employment-related information

Current or past job history or performance evaluations and recorded video interviews.

Yes

Non-public education information (per the Family Educational Rights and Privacy Act (20 USC Section 1232g, 34 CFR Part 99))

Education records directly related to a student maintained by an educational institution or party acting on its behalfs, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Yes

Inferences are drawn from other personal information

The profile reflects a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

Yes

As a Consumer under the CCPA, you have the right to request from Easy Marketing all the data collected by Easy Marketing in the preceding 12 months.

For Business Partners and users located in South Africa, please take note of the following:

 

In terms of section 1 of the Protection of Personal Information Act, 2013 (“POPI”), “personal data” or “personal information” includes “information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing, juristic person.”

 

The corresponding legal grounds and conditions for lawful processing of personal data in South Africa are contained in Sections 8 to 25 of POPI and relate to “Accountability”,; “Processing limitation”; “Purpose specification”; “Further processing limitation”,; “Information quality”; “Openness”; “Security safeguards” and “Data subject participation”.

 

In terms of section 69 of POPI, the processing of personal information of a data subject for direct marketing using any form of electronic communication, including automatic calling machines, facsimile machines, SMS or email, is prohibited unless the data subject has provided consent to the processing, or is, subject to other conditions, an existing customer of the responsible party.

 

For purposes of a Data Subject exercising its rights to further enquiries and the exercise of its rights concerning access, objection to, and complaints in respect of the processing of personal data, the contact particulars of the Information Regulator of South Africa are as follows:

 

Contact Person: Alice Sheng

Email: informationofficer@easymarketing.uk

Contact: +44 07360058886

Address: Covent Garden, 71-75 Shelton Street, London, United Kingdom, WC2H 9JQ

 

This section applies and provides you with further information if the processing by one of our companies is located within the borders of the People’s Republic of China (“PRC”) or concerns the data of individuals within the borders of the PRC.

 

Processing of sensitive personal information

 

According to the PIPL, sensitive personal information means personal information that, once leaked or illegally used, may easily cause harm to the dignity of natural persons and grave harm to person or property security, including information on biometric characteristics, religious beliefs, specially-designated status, medical health, financial accounts, individual location tracking, etc. as well as the personal information of minors under the age of 14.

In addition to the payment data mentioned in section 2 of this Data Private Notice, we will, in principle, not process your sensitive personal information. However, suppose your sensitive personal information will proceed. In that case, we will notify you about the necessity of processing and its effects on the individual’s rights and interests and obtain your specific consent if applicable.

 

Transfer and disclosure of personal data

 

Following the requirements defined in Article 23 of PIPL, in additionally to the contents mentioned in section 4, we, in principle, will not transfer or share your personal information with third-party controllers unless (1) obtain your specific consent if applicable, or (2) to fulfil the statutory duties under local laws and regulations.

 

International Transfer

 

You acknowledge that your data will be transferred and proceed outside of PRC. We will follow the applicable laws and decisions the competent authority imposes and ensure that your data is protected in a manner consistent with the PRC Personal Information Protection Law. If you or the company you work for is a Business Partner, please be aware that Easy Marketing is a multinational company. To conclude or fulfil the contract/agreement with you or the company you work for, you understand and agree that we may transfer your personal information to foreign-affiliated companies.

 

Legal basis of the processing

 

The PIPL requires us to provide you with information on the legal basis of processing your personal data.

The legal basis for our processing is:

  • PIPL Article 13(2) (“Contract Performance”);
  • PIPL Article 13(3) (“Statutory duties and responsibilities”)
  • PIPL Article 13(6) (“Process publicly available data”);
  • PIPL Article 13(1) (“Consent”)

Usage by Children

 

This Online Offering is not directed to children under fourteen (14). We will not knowingly collect personal data from children under the age of fourteen (14) without prior parental consent if applicable law requires. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent according to local law and regulations or to protect a child.

 

Contact Person: Leo Wei

Email: leowei@easymarketing.uk

Contact: +86 15527729050

Address: Room 02, 3rd Floor, Building 5, Wuhan International Center, No. 1, Guanshan 2nd Road, Donghu New Technology Development Zone, Wuhan, China

This Privacy Policy may be amended periodically to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy, we will update the “Effective Date” at the top. We recommend that our users periodically review our Privacy Policy to ensure they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. In addition, you may contact a supervisory authority if you feel we have not addressed your concern adequately. You also have the right to make a complaint to a supervisory authority directly.

 

Additionally, Easy Marketing is part of a global company operating in many different countries. Suppose you have questions not answered in this Policy concerning how we use your personal information or wish to raise a complaint regarding how we may have handled your personal information. You may also contact Easy Marketing’s Data Protection Officer in that case.

 

Contact Person: Alice Sheng

Email: informationofficer@easymarketing.uk

Contact: +44 07360058886

Address: Covent Garden, 71-75 Shelton Street, London, United Kingdom, WC2H 9JQ

Updated and Effective Date: 4 October 2022