General Data Protection Regulations

GENERAL DATA PROTECTION REGULATIONS-PRIVACY NOTICE

Background

ECNX Developments understands that your privacy is important to you and that you care about how your personal data is used. Werespect and value the privacy of all of customers, clients and associatesand will only collect and use personal data in ways that are described here, and in a way that is consistent with ourobligations and your rights under the law

1. Information About ECNX Developments

ECNX Developments is a researchand development operation, running as a limited company, registered in England and Wales under company number 09433762.
Our registered office is ECNX Developments Limited, 5 Theale Lakes Business Park, Moulden Way,Sulhamstead, Reading, Berkshire, United Kingdom, RG7 4GB.
Data Protection Officer: Steven Parham(Technical Consultant)
Email address: gdpr@ecnxdev.co.uk
Telephone number: 0207 183 1238




2. What does this notice cover?

This Privacy Information explains how weuse your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.




3. What is personal data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that weuse is set out in Part 5.




4. What are your rights?

Under the GDPR, you have the following rights, whichwe will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11

b) The right to access the personal datawe hold about you. Part 10 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contactus using the details in Part 11 to find out more.

d) The right to be forgotten, i.e. the right to askusto delete or otherwise dispose of any of your personal data thatwehave. Please contactususingthe details in Part 11 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object toususing your personal data for a particular purpose or purposes

g) The right to data portability. This means that, ifyou have provided personal data tousdirectly,weareusing it with your consent or for the performance of a contract, and that data is processed using automated means, you can askusfor a copy of that personal data to re-use with another service or business in many cases

h) Rights relating to automated decision-making and profiling.Part 6 explains more about howweuse your personal data, including automated decision-makingand profiling.




For more information about our use of your personal data or exercising your rights as outlined above, please contactususing the details provided in Part 11.Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.If you have any cause for complaint aboutouruse of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office

5. What personal data do we collect?

We may collect some or all of the following personal data:

• Name
• Address
• Email Address
• Telephone Number
• Business Name
• Job Title
• Profession
• Payment Information



Your personal data is not obtained from third parties and is only given to us by you, our clients, customers and associates





6. How do we use your personal data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary forourperformance of a contract with you, because you have consented toour use of your personal data, or because it is inour legitimate business interests to use it. Your personal data will be used for the following purposes:



• Providing and managing your account.
• Supplying ourproductsand/orservices to you. Your personal details are required in order for usto enter into a contract with you
• Personalising and tailoring ourproducts and/or services for you.
• Communicating with you. This may include responding to emails or calls from you
• Supplying you with informationby email and/orpost that you have opted-in to (you may unsubscribe or opt-out at any time bye mailing us at gdpr@ecnxdev.co.uk).
• With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text messageor post with information, news, and offers on ourproductsand services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.



Wedo not use automated systems for carrying out decision-makingand profiling. If at any point you wish to query this, the GDPR gives you the right to do so. Please contact usto find out more using the details in Part 11.

7. How long will wekeep yourpersonal data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• Customer, client and associate information is retained for a period of seven years, whereupon it is reviewed,and whenrequiredand appropriate to do so, deleted.




8. How and where do we store or transfer your personal data?

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following

• Regular reviews of data and information held by us in relation to clients, customers and associates.
• Regular system security updates and patches in accordance with intelligence received from the UK government and other reliable security consultancies that supply credible information on potential system vulnerabilities and other threats to data security.




9. Do we share yourpersonal data?

In short, no. However, in some limited circumstances, we may be legally required to share certain personal data, which might include yours, if weare involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.




10. How can I access my personal data?

If you want to know what personal datawehave about you, you can ask usfor details of that personal data and for a copy of it (where any such personal data is held). This is known as a “Subject Access Request

All Subject Access Requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell useverything weneed to know to respond to your request as quickly as possible.

There is not normally any charge for a Subject Access Request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover ouradministrative costs in responding

Wewill respond to your subject access request withinafortnightand, in any case, not more than one month of receiving it. Normally,weaim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date wereceive your request. You will be kept fully informed of ourprogress.




11. How to contact us

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Steven Parham):
Email address: gdpr@ecnxdev.co.uk
Telephone number: 0207 183 1238.
Postal Address: ECNX Developments Limited, 5 Theale Lakes Business Park, Moulden Way,Sulhamstead, Reading, Berkshire, United Kingdom, RG7 4GB




12. Changes to this privacy notice

We may change this privacy notice from time to time. This may be necessary, for example, if the law changes, or if we changeourbusiness in a way that affects personal data protection.
Any changes will be made available on our web pages, press releases, social media feeds and via email bulletins where appropriate.