Website - User Terms Privacy And Cookies Policy - Version Of 25 May 2018 About This Privacy Policy is intended to describe why and how BeMyEye Holdings Ltd, and its subsidiaries (collectively “BeMyEye”), as Data Controller (“BME”, “Company” or “Data Controller”), collects and processes the personal data relating to the user (“User”) who interacts with the website https://www.bemyeye.com (“Website”) and with the various services offered through the website. The information contained in this Privacy Policy is provided pursuant to art. 13 of the EU Regulation of 27 April 2016 n. 679 (“Regulations”), under the applicable provisions of the law, for the protection of personal data as per the Guidelines set out by the European authorities. The information related to the processing of data concerns only the user activity on the Website, and does not extend to the processing operations performed by third parties of other sites the User may visit via links. With respect to these further processing operations, the Company assumes no responsibility, and the User must refer to the individual Privacy Policy of third party websites. 1. Owner And Place Of Processing The data controller is BeMyEye Holdings Ltd, with its registered office at 40 Islington High Street, London N1 8XB, United Kingdom, and with its individual subsidiaries located in the territories of the European Union. The full list of locations is available on http://www.bemyeye.com. The data is mainly processed at the premises of the Data Controller, by technical staff of the appointed company in charge of processing, within the territory of the European Union, but data related to the services offered by third parties may be processed outside the the European Union. In the case of transfer of data to countries that do not uphold a standard of protection equivalent to that of European Union, the Company undertakes to adopt the necessary measures for this transfer. 2. Responsible For The Protection Of Personal Data (Data Protection Officer) The Data Protection Officer (“Data Protection Officer” or “DPO”), designated in accordance with the provisions of the Regulations, can be contacted at the following address: DPO@bemyeye.com. 3. Methods Of Data Processing The Company processes User data by adopting all appropriate security measures to prevent unauthorized access and the disclosure, modification or destruction of unauthorized data. The processing is carried out with both manual and computerized tools and is strictly limited to the purposes indicated. 4. Purposes Of Data Processing And Legal Basis Of Processing The Company, through the Website, may process User data for the following purposes: a. For the receipt of job applications via the “Careers” section. The Company offers the User the opportunity to send an e-mail application via the “Careers” section of the website. To this end, the Company will acquire and use the information provided by the User exclusively for the purposes of selection and management of applications. In every case, the User is encouraged not to include sensitive data in his or her CV (for example that which concerns health status, political opinions, sex life, etc.), and is encouraged only to include data that is strictly necessary according to the law for the purposes of selection and evaluation of the CV. Furthermore, the Company may request that the User consent to the sharing of his or her CV with other companies in the BME Group, and to be contacted by other companies in the BME Group (as autonomous data controllers) in relation to selection and recruitment. b. Contact the Company. The Company offers the User the ability to communicate with the Company, and to send requests for information on the Company’s activities, initiatives and services. In this regard, the personal data provided by the User (e.g. email address, telephone number and / or other information provided by the User) will be processed by the Company, in order for the company to grant the User’s request. The granting of the User’s request exhibits the legal basis of the processing, since the company cannot grant the User’s request without the User’s voluntary provision of personal data. c. Access to free reports. The Company offers the User the ability to download its research reports, after filling in the relevant form. Again, the granting of the User’s request exhibits the legal basis of the processing, since the company cannot grant the User’s request without the User’s voluntary provision of personal data. d. Marketing objectives of BME. The Company sends out information about its products and services, and is interested in offering the User the opportunity to participate in events and workshops organized by the Company or by its commercial partners. By providing their data to download reports, the user is recorded in the Company database as a subject interested in Company services / products. Information sent to the User by the Company will be in line with the User’s requests and with the products they use. The User can unsubscribe by clicking on “unsubscribe” at the bottom of the emails sent by the Company. The legal basis of the processing is exhibited by the Company deeming the User to have shown genuine interest in the Company’s services. The User can at any time withdraw their consent by contacting the Company at the addresses indicated in the section “Rights of the User and Contacts”, as well as via the relevant link in the emails received. e. Pursuit of the legitimate interests of the Company and / or third parties. The User’s data may also be used for the exercise of the rights and legitimate interests of the Company and / or third parties, for example the right to defence in court, the management of complaints and litigation, the possible recovery of claims, and prevention of fraud and / or illegal activities. In these cases, data that is relevant to the pursuit of such legitimate interests may be used. Any refusal from the User to provide their personal data would prevent the Company from granting the User’s request for information. f. Comply with legal obligations and / or applicable regulations. The Company may also use the personal data provided by the User or otherwise acquired during the User’s interaction with the Website for purposes related to compliance with legal obligations and national and European Community regulations. Instructions given by authorities on how to comply with such regulations exhibit the legal basis of the processing, for which the prior consent of the user is not necessary. g. Use of the services by the Company’s customers: the Company’s customer has the ability to use the services offered through the Company’s Website. BME’s client companies can assign profiles of differing levels of authorization to their employees or company contacts. The Company provides access to these users, and monitors and controls their access, not only for security purposes but also to enable analysis and improvement of the service. The data and information collected through use of the service will be also used by the Company for the purpose of evolutionary maintenance of the platform. h. Perform aggregated statistical analysis on an anonymous basis in order to improve the services offered by the Company through the Website. In this case, consent from the User will not be necessary, as the processing will be carried out on anonymous data only. 5. Categories Of Data Processed The Company receives and collects, through the Website, information related to the User visiting the Website. In particular, the Company acquires and processes the following information: 5.1 Data collected through navigation and through cookies When the User visits the Website, certain data is collected, such as the pages viewed, the links or buttons clicked, the date and time of access, the IP address of the User, and the internet browser and the operating system being used (so-called “browsing data”). This navigation data, along with data held by third parties, could by its very nature allow the user to be identified. However, the Company uses this data for the sole purpose of obtaining statistical and anonymous information on the use of the Website, which may then be used to help with the maintenance of the Site. The navigation data could also be used to ascertain responsibility in cases of computer crimes carried out against the Website. For more information regarding the collection of the User’s data through cookies and similar technologies, please refer to the Cookies Policy paragraph. 5.2 Data provided voluntarily by the User The Company limits the collection of information voluntarily provided by the User to data that is necessary for the purposes described in paragraph 3 above. The Company may collect and process additional personal data, voluntarily provided by the User, in connection with the services offered by the Website. For example, in the event that the User contacts the Company to report malfunctions on the Site, the data will be processed by the Company solely for the purpose of rectifying the malfunction. 6. Communication Of Data To Third Parties The data provided by the User as well as that collected by the Website (for example the IP address of the User) may be communicated for the purposes and methods described in this Privacy Policy, to the following third parties: • companies of the BME Group, for administrative-accounting purposes, for the pursuit of the legitimate interests of the Company and / or third parties, and for purposes of execution of the services expressly requested by the User; • companies, collaborators, consultants or freelancers used by the company to perform technical or organizational tasks (such as IT service providers), or with which the Company collaborates (including other BME companies), for the purpose of providing its services or carrying out communication activities; • persons, companies or professional firms that provide assistance and advice to the Company, with particular but not exclusive reference to accounting, administrative, legal, tax and financial matters; • subjects whose right to access data is recognized by legal provisions or by authorities’ orders. The subjects belonging to the above categories will use the data as independent data controllers in accordance with the law or data processors duly appointed by the Company. These subjects may be established in EU and non-EU countries. In particular, if said subjects are established in non-EU countries, the Company adopts the measures outlined by the Regulations to legitimize the transfer of personal data to them, and specifically in the United States by virtue of the accession of suppliers to the program Privacy Shield. The list of subjects to whom the data are or may be communicated, as well as the privacy measures adopted to legitimize non-EU transfers, can be requested from the Company by contacting the addresses given in the “User Rights and Contacts” section. 7. Data Retention The data is processed only for the time necessary to carry out the activities indicated in paragraph 3 above. In particular, the Company will delete the personal data of the User who has requested it be deleted by writing to privacy.users@bemyeye.com. In the absence of such a request, the Company will: – delete the personal data of a User that has applied for positions of employment in the Company 12 months after the application date if the User does not establish a working relationship with the Company; – delete the data collected for marketing purposes 24 months after the request to unsubscribe; – delete the data of Users who connect to the Website to use purchased services after 24 months of inactivity. 8. Rights Of The User And Contacts The User may exercise where applicable, in the cases expressly set out by law, the rights outlined by the Regulations. In particular, the User has the right to: • request confirmation that the Data is being processed and, in this case, ask the Data Controller to access the information related to the processing; • request the correction of inaccurate or incomplete Data; • ask the Data Controller to delete the Data; • request the limitation of processing; • request to receive, in readable format, the data concerning him/her or to directly transmit the data to another holder, where technically feasible (“data portability”). The User also has the right to object, in whole or in part, for legitimate reasons, to the processing of personal data concerning him or her. These rights can be exercised directly by sending a request to the following email address: privacy.users@bemyeye.com. Finally, if the user believes that the processing of their data violates the legislation on the protection of personal data, they have the right to lodge a complaint with the Authority for the protection of personal data. 9. Collection Of Data Through Cookies A cookie is a small text string that the visited sites send to the browser of the User’s computer, where it is stored and then sent back to the site on the next visit. Cookies are used by the Company to operate the Website or to improve its performance, but also to provide information on the Website or on the User’s navigation. The Website uses cookies both for technical purposes and for other purposes: while technical cookies are used as strictly necessary for the technical functioning of the Website as well as to provide the service expressly requested by the User (e.g. language setting, etc.), cookies for other purposes (e.g. profiling cookies, analytical cookies) are used to perform behavioural analysis of the User on the Website, in order to improve its contents and send advertising material in line with the User’s preferences. 9.1 Technical cookies Technical cookies are essential to allow the User to move within the Website and to use its features, and for the site to remember the user’s choices (e.g. language, country of origin, etc.), to distribute requests on multiple servers, to store data when the User gives his/her consent to certain options (for example by accepting the use of certain cookies) and to allow the User to view special content such as a video through Adobe Flash Player. These cookies last 12 months and do not require the consent of the User. 9.2 Performance and analytics cookies of the Company The use of these cookies is limited to the performance and improvement of the Website. These cookies allow the Company to recognize, measure and track visitors of the Website, thus allowing user experience improvements, for example by establishing if the User is able to easily find the desired information, or by identifying which aspects of the Website are of greater interest. These cookies are used by the Company to process statistical and anonymous analysis on how users navigate the site, the number of pages they visit or the number of clicks they make on a page while browsing. These cookies are regarded by the privacy legislation as technical cookies and therefore the User’s consent is not required. 9.3 Third-party Performance and Analytics Cookies The Company may also use analytical and performance cookies of third parties on the Website, for the same purposes described above, and in particular Google Analytics and WIX in order to analyse the browsing methods of Users on the Website, the number of pages visited by the User, and the number of clicks made by the User. The Company processes the results of this analysis only if the third party uses cookies in connection with the browser installed on the computer or on other devices used by the User to browse the Website. To activate these cookies, the User may choose to give his/her consent (which therefore represents the legal basis of the processing) through the mechanism shown in the alert banner displayed on the homepage / landing page of the Website. For information on how to manage the performance and analytics cookies installed by Google Analytics and WIX, and how to reject them, we recommend consulting the Privacy Policy of the companies indicated. 9.4 Profiling cookies installed by the Company These cookies are activated in relation to the User’s use of the site and the content displayed on the Website. This allows the Website to record and memorize the preferences expressed by each User during subsequent visits, to analyse the behaviour of the User on the Website and to customize certain aspects of the Website depending on the individual User, in order to improve the content and send advertising material (eg banner) in line with the User’s preferences. This type of cookie can also be used to limit the display number of a given advertisement and to help measure the effectiveness of an advertising campaign. The User’s consent is expressed through his/her choice to activate the cookies via the information banner displayed on the landing page. Furthermore, on its pages, as well as in the e-mails sent to the User, the Website could include web beacons and electronic images, “One pixel GIFs”, “clear GIFs” or “pixel tags”, that allow the Company to count the number of users who have visited the pages of the Website, or determine who has accessed the Website’s content. This allows the Company to obtain statistical data, and to identify the characteristics and content that most interest the individual Users in order to provide more personalized information. 9.5 Third party profiling cookies (retargeting) The Company makes use of some partners in order to show advertisements related to the Website on third party sites, and to allow partner advertising networks to display advertisements that take into account the preferences of Users who have requested information on the Website or viewed content on the Website. These cookies are used by Google and Linkedin to present to the User ads or sponsored contents on the latest services or contents of the Company. While the User browses the site, these cookies are also used to present the user with products that might be of interest based on the user’s browsing history. These cookies connect to the browser installed on the User’s computer or other devices used while browsing the Website. For information on how to manage these cookies, as well as how to prevent their use, we advise the User to consult the Privacy Policy of the indicated parties Finally, to learn more about profiling cookies on the Website and how to manage or disable those of third parties, the User can visit http://www.youronlinechoices.com. 9.6 Disabling cookies through the browser In addition to being able to choose whether to accept or reject all or part of the cookies used by the Website for further purposes through the mechanisms described in this Privacy Policy, in the future, if desired, the User may also delete the cookies placed on the Website via the settings of the same browser. Most browsers are set to accept cookies. However, the User can configure his or her browser to restrict the number of cookies accepted or to block all cookies, by changing the browser settings in the following ways: Microsoft Internet Explorer Click on the ‘Tools’ icon in the upper right corner and select ‘Internet Options’. In the pop-up window select ‘Privacy’. Here the User can change the cookie settings. Google Chrome Click the “wrench” icon in the upper right corner and select ‘Settings’. At this point select ‘Show advanced settings’ and change the ‘Privacy’ settings. Mozilla Firefox From the drop-down menu in the upper left corner, select ‘Options’. In the pop-up window select ‘Privacy’. Here the User can adjust the cookie settings. Safari From the drop down setting menu in the upper right corner select ‘Preferences’. Select ‘Security’ and here the User can adjust the cookie settings. It should be noted, however, that disabling the use of all cookies on the Website (including technical ones) will compromise some features. 9.7 Further information about cookies The website http://www.allaboutcookies.org contains instructions for managing cookies on the most popular browsers; alternatively, you can consult the documentation attached to the software used on your device. 10. Changes To The Privacy And Cookies Policy The Company reserves the right to make changes to this Privacy Policy at any time, by giving notice of it by publishing it on the Website. We invite the User to check these updates on the Website. If the changes are particularly significant and / or impact the User’s rights, the Company may communicate them to the User through a different method (for example by sending an email). Want To See The Magic In Action? Click here to have a look at our products: DEMO BeMyEye 6-8 Tokenhouse Yard London, United Kingdom NEWSLETTER About us Who we are Career Customer Stories Resources Blog Products List of features Demo Pricing Client Log In Useful links Contact us Website archive Website - Terms of service © BeMyEye Holdings Ltd, all rights reserved Made with by BeMyEye