1. WHO WE ARE
Easol Trading Limited ('Easol', 'we', 'us' or 'our') is a private company limited by shares, registered in England and Wales with Company Number 09245218 and registered office address at 34 High Street, Aldridge, Walsall, West Midlands, United Kingdom WS9 8LZ.
By submitting personal data to Easol you acknowledge and accept the practices described in this Policy.
4. PERSONAL DATA THAT EASOL COLLECTS FROM YOU
The personal data we collect from you includes:
- The name and contact details that you provide at the time of making an enquiry, when you register as an Easol customer, or otherwise submit personal data via the Website;
- Your payment and address details;
- Your marketing preferences, including any consent you have given us, which may be adjusted or withdrawn at any time;
- Information you provide when you complete surveys that we use for research purposes;
- Your browser or device information; and
- Information about your use of the Website.
5. PROCESSING ACTIVITIES
The following table summarises the types of data processing activities we undertake in relation to personal data subject to this Policy:
|Information we Process||Purposes for Processing||Legal Basis for Processing|
|Publicly available information||To contact event companies and tour operators to enquire whether they are interested in becoming Clients of Easol.||Our legitimate interests, namely the pursuit of our own marketing and business development efforts.|
|Any personal data you provide to us on or after registration, such as names, contact details, occupation, purchase history, etc.||
|Information you generate when you visit our website or our apps||
|Our legitimate interests, namely monitoring and improving our website and services, and your consent whenever required (such as for non-essential cookies).|
6. THIRD PARTIES
You understand and acknowledge that we use the services of third party suppliers to facilitate our business and our Services, including but not limited to customer relationship management systems, holiday/travel agencies, event companies and tour operators. These suppliers have given contractual undertakings that they will safeguard personal data disclosed to them in the course of providing such services and have agreed to be held liable in the event of any breach of data protection law for which they are responsible. We reserve the right to disclose personal data to Clients or suppliers for the purposes of fraud monitoring and reducing credit risk. Our legal basis for this processing is our legitimate interests, namely the protection of our own and our clients’ businesses and legal rights.
In addition to these suppliers, there are other third parties with whom we may need to share your personal information for the reasons set out below:
|Third Party||Purposes for Processing||Legal Basis for Processing|
|Companies within our corporate group (including affiliates and ultimate beneficial owners), or who acquire a controlling interest in our business or its assets||To facilitate the provision and promotion of the Services and to monitor business development.||The performance or negotiation of the contractual relationship between us and our Clients, our legitimate interests, specifically the pursuit of our own marketing and business development efforts, and your consent whenever required.|
|Suppliers, such as CRM systems and marketing agencies||To facilitate the provision and promotion of the Services.||The performance or negotiation of the contractual relationship between us and our Clients and our legitimate interests, specifically the pursuit of our own marketing and business development efforts.|
|Professional advisors, such as accountants and solicitors||Only when necessary, and limited to what is necessary.||Our legitimate interests, namely the proper administration of our business, or fulfilling our legal obligations to Clients or users of our Services or in relation to enforcing or defending legal claims.|
7. INTERNATIONAL TRANSFERS
We work solely with world-class suppliers, some of whom have branches outside the European Economic Area (‘EEA’). Any transfers of your personal data outside the EEA take place only subject to appropriate safeguards as provided in data protection law. These safeguards are intended to secure your rights as a data subject with respect to any relevant non-EEA domiciled entities.
Personal data may in limited circumstances be shared with our affiliates in order to provide and/or develop our Services or where one of the other legitimate interests identified above applies. Personal data collected in the EEA may be accessed from our US affiliate Easol, Inc. This is usually carried out for the purposes of providing 24/7 customer support or in relation to product development. Easol assumes responsibility for the security of personal data that is accessible by our overseas affiliates.
8. YOUR RIGHTS
We are committed to guaranteeing the statutory rights of individuals. If you send us a request regarding your rights under data protection law we will respond within one month of receipt and, where possible, address your request within such time. Where necessary, this period may be extended by up to a further 60 days.
The persons to whom this Policy applies are under no statutory or contractual obligation to provide personal data to Easol. However, should you decide to submit personal data to us, you will have the following rights, as a data subject, under data protection law as summarised below:
|the right to be informed||the right to access||the right to rectification|
|the right to erasure||the right to restrict processing||the right to object to profiling|
|the right to data portability||the right to complain to the Information Commissioner's Office||the right to withdraw consent (e.g. to direct marketing)|
Please note these rights may not always apply, for example if fulfilling your request would require us to reveal personal data relating to another user, or if you ask us to delete information which we are required by law to keep or have a compelling legitimate interest in keeping. If this is the case, then we will let you know at the same time as we respond to your request.
Easol does not engage in automatic decision making which is capable of producing legal or other significant effects for individual data subjects.
Detailed information on the content and the means to exercise your rights is provided by the United Kingdom's Information Commissioner's Office.
9. RETENTION PERIOD
Easol operates an internal Data Retention Policy. In respect of all personal data within the scope of this Policy, Easol will retain such personal data until you advise us to securely dispose of it, or until it becomes outdated, or it is no longer appropriate for us to retain such data. It is your responsibility to inform Easol of any material changes to your personal data to ensure it is accurate. Outdated personal data is periodically deleted in accordance with our Data Retention Policy which is available for review upon request.
10. SECURITY MEASURES
Easol operates an internal Information Security Policy. We have taken technical and organisational measures to ensure our own and our suppliers' information security standards are appropriate to the risks associated with the personal data processing we undertake. Our security objectives include guaranteeing the confidentiality, integrity and availability of personal data and the resilience of the systems that process it. Our Information Security Policy is available for review upon request.
It is your responsibility to keep the password provided to you on registration secure and confidential at all times. We will not be held liable for any breach of data protection law arising from your improper use of the Website, or due to your password details being disclosed to any third party. In the event you have reason to believe your interactions with us are not secure, or the integrity of your login has been compromised, please contact us immediately.
11. CHANGES TO THIS POLICY
We reserve the right to amend this Policy from time to time. You will be informed of any material changes without delay.
We reserve the right, in the event that we buy or sell all or part of our business or assets, to disclose personal data held by us to the prospective seller or buyer of such business or assets.
In relation to any queries about this Policy or any other data protection matters, please contact: firstname.lastname@example.org