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Privacy policy

Last updated 10 May 2018.

Employment Conditions Abroad Limited (“ECA”) is committed to respecting the privacy of subscribers to ECA Services, visitors to its website and its potential customers. This Privacy Policy sets out how ECA (which includes the ECA group of companies) uses and protects personal data and how ECA complies with European Union data protection requirements as implemented into UK data protection law. This Privacy Policy applies to all ECA’s dealings with subscribers and visitors to all ECA websites operated by ECA out of the UK. It also applies to personal data about prospective customers and that we collect when someone contacts us with an enquiry. You can access this policy via our homepage and from the bottom of every page of the public access website by clicking on the appropriate link. If you have any questions or concerns in relation to this Privacy Policy, please contact our Data Management Team in accordance with the Contacts and Complaints section at the bottom of this page before using this website. We may change this Privacy Policy from time to time (please see the Revisions to this Privacy Policy section at the bottom of this page).

Please note that in this Privacy Policy, references to "we" or "us" includes ECA and the ECA group of companies.

This policy explains how we may collect personal data about you and explains why and how we use it. It also outlines some of the security measures that we take in order to protect your privacy and informs you about the rights you have in respect of your personal data that we use.

Direct marketing

When we first obtain personal data from you when you create an account on our website or when you take a new service from us, we will give you the opportunity to indicate if you do or do not (as applicable) wish to receive marketing information from us, our commercial partners and from carefully selected third parties about other services or products (including promotions and special offers, new or improved products, services or seminars and promotional offers) and other information which we believe may be of interest to you. Normally this will be done by way of a tick box (to opt in or opt out as appropriate) on a registration form or contract on this website.

If your employer is a subscriber, you will automatically be updated with relevant information about your employer’s data subscription unless you have asked us not to contact you.

Unless we are otherwise permitted to do so by law, you will not be sent such marketing information if you indicate to us in the ways set out above that you do not wish to receive it.

If we identify you as a potential customer (for example, if you've attended an event we've sponsored) we may contact you for marketing purposes, but you always have the right to ask us not to use your personal data for marketing purposes (for example, you'll be able to unsubscribe from any marketing emails we send you).

Such marketing information may be sent to you by:

  • email
  • telephone
  • SMS text message and/or any other form of electronic messages
  • mail, or
  • any other method which becomes relevant from time to time.

You can change your mind at any time about whether or not you wish to receive direct marketing and you can do this by contacting us in accordance with the Contacts and Complaints section at the bottom of this page. In addition, if you receive direct marketing by email, SMS or any other form of electronic message, you will be reminded at that time that you can request a change to your preferences.

If you do change your mind about direct marketing, we would reflect this on our systems this rather than removing your name or contact details from our database(s) entirely. In other words, your ‘preferences’ will be changed as soon as reasonably possible so that you no longer receive direct marketing from us or be profiled for direct marketing purposes.

Collection of information

We collect and hold personal data (this includes your name, job title, company name, address, telephone number, email address, age and gender, personal or professional interests, demographics and experiences with our products and/or services) that you provide us with when:

  • you register on this website
  • you or your employer agree to buy a product or service from us (and in doing so become a registered user of our website)
  • you sign up for an event or conference made available to you through our website
  • you submit data to us for analysis through the questionnaires on this website, or
  • you contact us with an enquiry or in response to a communication from us.

In addition, we will collect and hold personal data (this includes the name, job title, company name, salary, marital and tax status, family size and home and host location) about your staff members or employees if you enter such information into this website, for example, when running calculations.

We also collect and hold information about you if we identify you as a potential customer (this includes your name, job title and email address) which we obtain from publically available sources and that is passed onto us by third parties, such as organisers of events we sponsor.

Some of the personal data that we ask you to provide will be compulsory and some will be optional. We will make the distinction clear at the point at which we ask for personal data from you. Where information is compulsory, this is because we need it to enable us to provide our services or deliver your online purchases to you. If you do not provide this compulsory information to us, you may not be able to register with us or complete online purchases.

We may combine information that we collect about you through this website with information that you provide to us by other means or that is provided to us by third parties, such as delegate lists provided from events that we sponsor or from publically available third-party sources. We may store that information together in a combined database or in separate databases.

For the personal data described above, ECA‘s legal status under data protection law is a controller. Controller is a legal term which signifies the person who controls what to do with any given personal data. As data controller ECA has registered with the Information Commissioner’s Office and our registration number is ZA231623.
If you purchase goods or services from this website and if you wish to pay by debit or credit card, you will be directed to the website of WorldPay, a third party. WorldPay will collect information from you for the purpose of the transaction including your debit or credit card information (ECA will not collect any such information from you). WorldPay’s own privacy policy will apply to the information that it collects. You should ensure that the terms of the WorldPay privacy policy are acceptable to you before you submit your information to WorldPay. You can do this by clicking on the appropriate link prior to confirming that you wish to proceed with the transaction.

You may in some circumstances be able to select the option ‘send me an invoice’ as an alternative to making payment through WorldPay. In this instance, ECA will process your payment and it will be ECA not WorldPay which will collect and use information from you for this purpose.

If you access our services via your employer’s data subscription, we will process any personal data you submit while using that subscription in order to provide a service to your employer and we act on their instructions. Before using a service of ours to which your employer has a subscription, you should make sure you understand how your employer will use that personal data.  If you have any questions about the use of personal data in connection with that subscription service, you should contact your employer.

Why we use your personal data and our lawful bases

Under data protection legislation we must have at least one lawful basis for each use of personal data. The reasons we use your personal data and the lawful bases we rely on to do so are as follows and as set out in the table below.

1. Where we have to collect personal data from you and/or use it in order to provide you the goods and services which you have purchased or signed up for, our lawful basis is processing necessary for the performance of a contract with you (necessary for a contract).

2. Where our use of your personal data is a benefit to us or a third party and it does not cause you unjustified harm, our lawful basis is processing necessary for our (or a third party’s) legitimate interests (legitimate interests). Where we’ve indicated that we rely on this legal basis, you have the right to object to us continuing to use your personal data for this purpose if you believe that your particular circumstances mean you are unjustifiably prejudiced by this use. You can do that by contacting us.  This right is not absolute though, where we have a compelling reason we may be able to continue to use your data for that purpose.

3. Where we ask for your permission to use your personal data in a certain way, our lawful basis is consent (consent). If we request your consent and you do not give it, we will not use your personal data in that way. You have the right to withdraw any consent that you have given at any time. You can do that by contacting us, or by any other method we inform you of in this Privacy Policy or when we seek your consent.

Purpose
Lawful basis
To register you on our website and to administer our website services including to process requests that you have made, for example, to confirm attendance at training course or events and to support our products and services.
Necessary for a contract.
To enable us to fulfil our obligations under any contract with you (including any sale to you of our products or services) and as part of our customer care procedures related to any such contract.
Necessary for a contract.
To verify your details for security purposes.
Necessary for a contract.
To help identify you when you telephone us to make an enquiry.
Necessary for a contract.
Subject to the Direct Marketing section of this Privacy Policy, to contact you by mail, telephone and email about other, new or improved products, services, training courses or events and promotional offers and other information which we believe may be of interest to you.
Legitimate interests (sending our customers marketing about our similar products and services is a commercial benefit to us and helps our customers keep up to date with other products they may be interested in). Our customers always have the right to opt-out of our use of their personal data for direct marketing purposes.
To contact you for marketing purposes on behalf of our commercial partners or selected third parties or to pass on your details to those parties for them to send you direct marketing.
Consent.
To carry out marketing analysis and database profiling aimed at improving the quality of products and services offered to you (including asking you for your opinions on our products and services and carrying out surveys).
Legitimate interests (both ours, as it makes our marketing, products and services more effective and our customers because it helps them receive offers most likely to be relevant to them and allows them to provide us with feedback).
To conduct promotions and to make special offers.
Legitimate interests (both ours, to promote our products and services and our customers, to get good deals). We do not send these to customers who have opted out of direct marketing.
For internal record-keeping.
Necessary for a contact and legitimate interests (of ours, to keep track of our business operations).
To identify and record potential customers who may be interested in our products and services.
Legitimate interests (of ours, to enable us to grow our business).
To enable us to monitor, review and improve our products and services.
Legitimate interests (of ours, so we can make our services as user-friendly as possible and offer products and services which match demand).
To benefit from the services and expertise of third party service providers.
Legitimate interests (of ours, for service efficiency and our customers, so they experience a good quality of service).
To participate in benchmarking surveys.
Necessary for the purpose of a contract (between you and your employer); or consent.

In addition, we will also use your information when we are required to do so by law. Where that is the case, our lawful basis is processing necessary for us to comply with a legal obligation that we are under.

All of the above applies equally to the use of information about you for such purposes by any member of the ECA group of companies.

Who do we disclose your personal data to?

We may disclose your personal data in the following ways:

  • to members of the ECA group of companies
  • where it is necessary to enable any of our staff, employees, agents, contractors, suppliers or commercial partners to provide a service to us or to perform a function on our behalf
  • to our professional advisers
  • to carefully selected third parties for marketing purposes (but only where you have consented to this, please see the Direct Marketing section of this Privacy Policy), or
  • where it is necessary in order to pursue our legitimate interests.

We may disclose depersonalised data (such as aggregated statistics) about the users of our site in order to describe our sales, customers, traffic patterns and other site information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying information.

We may occasionally be required by law, court order or governmental authority to disclose certain types of personal data.  Examples of the type of situation where this would occur would be:

  • in the administration of justice; or
  • where we have to defend ourselves legally.

Finally, in the event of a reorganisation, sale or takeover we may need to disclose personal data to new entities within the group or potential acquirers and their advisers though we will do so on the basis that the information is kept in confidence and, if the reorganisation, sale or takeover takes place, used only in accordance with applicable law and this privacy policy.

When we make a disclosure of your personal data to any of our contractors, suppliers or commercial partners who are acting on our behalf, we will comply with data protection law by ensuring that there are contractual provisions in place, including, to ensure that any such third party:

  • does not use your personal data for any purpose other than purposes that we specify and in accordance with the purposes outlined in this policy; and
  • has appropriate security provisions in place in order to guard against unauthorised or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data.

Generally, we only store and use your personal data within the UK and other EEA countries. However, we may need to disclose your personal data to members of the ECA group of companies which are based outside the European Economic Area in Australia, Hong Kong and the USA. If personal data is transferred outside the UK and other EEA countries there is a risk that it will not be protected to an equivalent standard as in the UK, so, we will not do so until we have taken steps to ensure that your personal data will be afforded the same level of protection as that required from us by data protection law. We usually do this by standard contractual clauses or by a scheme approved by our data protection regulator as providing adequate protection (such as a scheme known as Privacy Shield, for transfers to US companies).

We will take all reasonable precautions to ensure that our staff and employees who have access to your personal data have received adequate training to ensure that they use that personal data only in accordance with this policy and with our obligations under data protection law. We may take disciplinary action against our staff and employees in the event of non-compliance, should we consider this to be appropriate.

How long do we retain your personal data?

We will not retain information about you for longer than is necessary for the purpose for which it was intended, or as required under any contract or by law.

If you become a registered user of our website and/or if you do attend an event or conference made available to you through our website, we will collect and retain your personal data for up to 7 years following the end of the service we provide to you or you close your account with us. If you do not do either of these but instead make an enquiry on our website we will retain your personal data for up to 7 years after your last contact with us.  These retention periods may be extended if any applicable statutory or regulatory obligation requires us to hold information for a longer period. We will endeavour to delete any personal data sooner where it is not necessary for us to hold this. If we've identified you as a potential customer, we will retain your details for as long as we reasonably believe our products and services may be of interest to you, which we review on an annual basis.

Your rights

You have the following rights in relation to your personal data:

  • a right of access to a copy of the information comprised in your personal data;
  • a right to access your personal data in machine-readable format and to request that we transfer this to a third party data controller;
  • a right to object to processing that is likely to cause or is causing damage or distress where we rely on the legitimate interest basis to use your personal data;
  • where we have sought your consent, a right to withdraw your consent at any time;
  • a right to ask us not to process your personal data for direct marketing purposes (including profiling for marketing purposes); and
  • a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed.

If you would like to exercise any such rights please write to our Data Management Team at the address in the Contacts and Complaints section of this Privacy Policy or submit your request using this form. If you contact us in relation to your rights we will do our best to accommodate your request or objection. Please note, however, that not all rights are absolute. Sometimes other legal obligations or third party rights will take precedence.

If you request a copy of personal data that we hold about you, we may require proof of ID.
You also have a right to claim compensation for damages caused by a breach of data protection legislation and you can make a complaint about our use of your personal data as set out in the Contacts and Complaints section below.

Please help us to ensure that the personal data about you that we hold is accurate and up to date. If you think that any personal data we have about you is incorrect or incomplete, please contact us. We will correct or update your personal data as soon as reasonably possible.

Cookies

We use cookies and web beacons to collect information about you online. Please read our Cookie Policy for further information on the cookies we use and how you can enable/disable them. 

Security

ECA places a high priority on the security of personal data. We maintain your subscription information (where applicable), the website and all associated data with reasonable electronic, technical, administrative and physical safeguards (as appropriate) to protect against loss, unauthorised access, destruction, misuse, modification and improper disclosure. Whilst we have done all of this, we cannot guarantee that your information collected through this website is secure.

Passwords are used on this website. Please help us to keep your personal data secure by not using an obvious login name or password, by changing your password regularly and by ensuring that you do not divulge your password to any other person. If you become aware or suspect that your password may be used unlawfully or without your consent please tell us as soon as possible by contacting our Data Management Team in accordance with the Contacts and Complaints section at the bottom of this page. At our sole discretion we may bar the use of your password from time to time due to security or other concerns or for general administration purposes.

Linking

ECA cannot protect your privacy once you leave its website through a link. In addition, other websites outside our control may link to this website. We are not responsible for the content, security, practices or privacy policies employed by other websites. We encourage you to carefully review these sites’ privacy policies so that you know how they will collect, use, and share your personal data. 

Revisions to this Privacy Policy

ECA may at any time revise these privacy terms and conditions. When we do, we will revise the "last updated" date at the top of this Privacy Policy and we will take reasonable steps to make you aware of any material changes to it. We also recommended that you revisit this page regularly to keep informed of our current privacy practices.

Contacts and Complaints

This website is owned and operated by Employment Conditions Abroad Limited (ECA), whose registered office is at New Brook Buildings, 16 Great Queen Street, London WC2B 5DG, England. Certificate of Incorporation No. 1030127.

If you have any questions of concerns about this privacy policy or how we use your personal data, we ask that you contact us in the first instance by e-mail at eca@eca-international.com or by post at the above address. We’ll do our best to resolve the matter. However, you do also have the right to lodge a complaint to the Information Commissioner’s Office at any time.