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Privacy policy
Last updated December 21, 2022
Thank you for choosing to be part of our community at EmpowerTheUser (ETU) Ltd., doing business as ETU (“ETU”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at hello@etu.co.
This privacy policy describes how we might use your information if you:
- Visit our website http://www.etu.co
- Engage with us in other related ways - including any sales, marketing, or events.
In this privacy policy, if we refer to:
- "Website", we are referring to any website of ours that references or links to this policy
- "Services", we are referring to our Website, and other related services, including any sales, marketing, or events.
The purpose of this privacy policy is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Services immediately.
Please read this privacy policy carefully, as it will help you understand what we do with the information that we collect.
Table of contents
1. What information do we collect?
2. How do we use your information?
3. Will your information be shared with anyone?
4. Who will your information be shared with?
5. Do we use cookies and other tracking technologies?
6. How long do we keep your information?
7. How do we keep your information safe?
8. Do we collect information from minors?
9. What are your privacy rights?
10. Controls for do-not-track features
11. Do California residents have specific privacy rights?
12. Do we make updates to this policy?
13. How can you contact us about this policy?
14. How can you review, update or delete the data we collect from you?
1. What information do we collect?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and Services, when participating in activities on the Website or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect can include the following:
Personal Information Provided by You. We collect CV and other job application data such as background checks; names; email addresses; job titles; and other similar information.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.
We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and usage data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and 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 Website (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 device you use to access the Website. Depending on the device used, this device 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 Website. 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. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
2. How do we use your information?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Website.
- Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.
- To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
- To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the "What are your privacy rights?" below).
- Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
3. Will your information be shared with anyone?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or 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 our business to another company.
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data about how you interact with the Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
4. Who will your information be shared with?
In Short: We only share information with the following categories of third parties.
We only share and disclose your information with the following categories of third parties. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled "How can you contact us about this policy?".
- Sales & marketing tools
- Retargeting platforms
- Data analytics services
- Ad networks
- Website hosting service providers
- Social networks
5. Do we use cookies and other tracking technologies?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.
6. How long do we keep your information?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy 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 policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
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 not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. How do we keep your information safe?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. We encrypt your data at rest in conformity with ETU's Encryption Policy. We are not using automated decision-making to process your data. 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, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
All personal data transferred outside of the EU must use one of the approved transfer mechanisms:
1 - Adequacy decision (see list of countries below)
2 - Appropriate Safeguards (In absence of adequacy decision)
2a - Standard Contractual Clauses (SCCs)
Either between Controllers or between Controller & Processor
2b - Binding Corporate Rules (BCRs) corporate rules within a multinational group
2c - Approved Codes of Conduct
2d - Approved Certification Mechanisms
2e - Legally Binding between public authorities or bodies
3 - Derogations for specific situations (article 49)
3a - Explicit consent from Data Subject
3b - Performance of Contract at Data Subject request
3c - Conclusion of Contract in the interest of Data Subject
3d - Important reasons of Public Interest
3e - Establishment, exercise or defense of Legal Claims
3f - Protect Vital Interest of Data Subject or other persons when giving consent is not possible
3g - Transfer from register intended to provide information to the public with conditions from Union or Member State law
Adequacy decision countries:
EU Countries including Norway, Liechtenstein and Iceland
Andorra
Argentina
Canada (commercial organizations)
Faroe Islands
Guernsey
Israel
Isle of Man
Japan
Jersey
New Zealand
Republic of Korea
Switzerland
United Kingdom (GDPR & LED)
Uruguay
8. Do we collect information from minors?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at hello@etu.co.
9. What are your privacy rights?
In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
The GDPR provides the following corresponding rights for individuals:
1. The right to be informed
Both data processors and controllers are now obliged to provide information to data subjects about the personal data being collected, how it is going to be used, who it will be shared with, for how long it will be kept and the purpose of its processing.
2. The right of access
With request, individual data subjects are entitled to confirmation that their data is being processed, access to that data as well as further information regarding any automated decision making, or the envisioned period of retention.
3. The right to rectification
With its corresponding principle in ‘accuracy’, data subjects hold the right to have personal data rectified should it be either inaccurate or incomplete.
4. The right to erasure
Also known as ‘the right to be forgotten’, this right allows data subjects to request the removal or deletion of data in the eventuality there is no compelling reason for its continued processing or availability. This right may in some circumstances also obligate, for instance, a search engine company to remove certain results, or limit their discoverability.
5. The right to restrict processing
Processing is any operation performed on personal data. This includes using, viewing, altering or deleting the data. Individuals may block or suppress processing of personal data for the following reasons: Inaccurate data, the unlawful processing of that data or a pending objection to processing the data by the data subject
6. The right to data portability
Allowing individuals to obtain and reuse their personal data across different services, this right means an individual’s data should be available in a commonly used machine-readable format, in a way which allows data not to be constantly resubmitted.
7. The right to object
Allowing individual to object (for certain reasons) to the processing of their personal data, as well as obliging organizations to inform individuals of this right at the time of first communication.
8. Rights in relation to automated decision making and profiling.
One of the more detailed and technical rights afforded under the GDPR, among other things, entitles individuals either opt out of automated decision-making processes, challenge decisions, and/or have automated decisions reviewed by a human.
In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you are resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here.
If you are a resident in Switzerland, the contact details for the data protection authorities are available here.
Cookies and similar technologies
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. To opt-out of interest-based advertising by advertisers on our Website visit here.
10. Controls for do-not-track features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.
11. Do California residents have specific privacy rights?
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 to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from our systems (e.g. backups, etc.).
12. Do we make updates to this policy?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.
13. How can you contact us about this policy?
If you have questions or comments about this policy, you may email us at hello@etu.co or by post to:
EmpowerTheUser (ETU) Ltd.
5th Floor, The Tower
Trinity Technology & Enterprise Campus
Pearse Street, Dublin
D02 K1W7
Ireland
The Information Commissioner's Office in Ireland and the United States can also be a resource for you.
14. How can you review, update or delete the data we collect from you?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here.
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This privacy policy was created using Termly’s Privacy Policy Generator.
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