LAST UPDATED: June 5, 2020
EDconsulting (“EDconsulting”, “we”, “us”, “our” or “us”) is committed to protecting the privacy and confidentiality of personal information that we may collect.
EDconsulting has created this privacy policy (“Privacy Policy”) to advise you of our information practices, such as the types of information we collect and how we may use that information, and to inform you of your privacy rights and how the law protects you. We encourage you to read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. By visiting any part of our Websites (as defined below) or by providing EDconsulting with Personal Information by any means, you accept and agree to the practices described in this Privacy Policy and your continued use of the Websites (following the posting of a revised privacy policy) means that you accept and agree to the terms of the revised privacy policy, so please check the policy periodically for updates.
Persons in the European Union (“EU”) should be sure to read the important information provided below in addition to the other provisions of this Privacy Policy.
I. IMPORTANT INFORMATION AND WHO WE ARE
II. THE INFORMATION WE COLLECT ABOUT YOU
III. HOW YOUR PERSONAL INFORMATION IS COLLECTED
IV. INTERACTIONS WITH THIRD PARTIES
V. THIRD PARTY ANALYTICS PROVIDERS AND AD SERVERS; ONLINE TRACKING
VI. HOW WE USE YOUR PERSONAL INFORMATION
VII. DISCLOSURE OF YOUR PERSONAL INFORMATION
VIII. YOUR CHOICES
IX. DATA SECURITY
X. USERS OUTSIDE SPAIN AND INTERNATIONAL TRANSFERS
XI. QUESTIONS
XII. ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN UNION
I. IMPORTANT INFORMATION AND WHO WE ARE
A. APPLICATION OF THIS PRIVACY POLICY
This Privacy Policy applies to www.edconsulting.biz and all other websites, features or online services owned or controlled by EDconsulting that post a link to this Privacy Policy (collectively, the “Websites”), whether accessed through a computer, mobile device or otherwise. Please note, however, that this Privacy Policy does not apply to your use of unaffiliated websites that link to our Websites. Once you link to another website (whether through an advertisement, service or content link), please be aware that we are not responsible for the privacy practices of those other websites.
B. PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy is intended to give you information about how EDconsulting collects and uses your Personal Information through your use of the Websites, including any information you may provide through the Websites when you register for an account, sign up to receive information or communications from us, purchase a product or service, or request further services or information from us.
It is important that you read this Privacy Policy together with any other privacy notices or fair processing notices we may provide on specific occasions when we are collecting or using Personal Information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements the other notices and is not intended to override them.
C. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF ANY CHANGES
This version was last updated on June 5, 2020 and historical versions can be obtained by contacting us. We reserve the right, at any time and without prior notice, to add to, change, update or modify this Privacy Policy simply by posting such change, update or modification on the Websites. Any such change, update or modification will be effective immediately upon posting on the Websites. However, unless you consent, EDconsulting will not use your Personal Information in a manner materially different from that set forth in our Privacy Policy posted at the time your Personal Information was collected.
Please review this Privacy Policy regularly to ensure that you are aware of any changes to our practices.
It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes during your relationship with us. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you contact us with changes, we will make good faith efforts to make the requested changes to our then-active databases as soon as reasonably possible. Please note, however, that information may persist internally for our administrative purposes and that residual data may remain on backup media or for other reasons.
D. THIRD PARTY CONTENT, LINKS TO OTHER WEBSITES AND EDCONSULTAS CONTENT FOUND OUTSIDE THE WEBSITES
The Websites may include links to third-party websites, plug-ins and applications, and certain content on the Websites may be hosted and served by third parties that EDconsulting does not control. When you click on a link to any other website or location, you will leave our Websites and go to another site and another entity may collect your Personal Information. We have no control over, do not review and cannot be responsible for these external websites or their content. Please note that the terms of this Privacy Policy do not apply to these external websites, their privacy statements or any collection of your Personal Information after you click on links to such external websites. We encourage you to read the privacy policies of each website you visit. Links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites. In addition, EDconsulting content may be included on websites and web pages that are not associated with EDconsulting and over which we have no control. These third parties may collect data through the use of their own cookies, pixel tags or other technology, independently collect information or solicit Personal Information, and may have the ability to track your use of their websites and services. EDconsulting is not responsible for the privacy practices or the content of any third party.
II. THE INFORMATION WE COLLECT ABOUT YOU
Personal information or personal data means any information about an individual from which that individual can be identified. It does not include information where identity has been removed (anonymous data). We and our third party service providers may collect, use, store and transfer different types of personal information about you which we have grouped as follows:
● IDENTITY INFORMATION includes name, username or similar identifier, title, date of birth and gender.
● DEMOGRAPHIC INFORMATION includes postcode, age and/or income.
CONTACT INFORMATION includes billing address, delivery address, email address and telephone numbers.
● FINANCIAL INFORMATION includes bank account and payment card details (applicable if any payments have been made).
TRANSACTION INFORMATION includes details of payments to and from you and other details of services you have purchased from us (applicable if any payment has been made).
TECHNICAL INFORMATION includes internet protocol (IP) address, your login details, browser type and version, time zone and geographical location settings, browser plug-in types and versions, operating system and platform and other technology or other unique identifier (a set of numbers or characters that is assigned to your computer, mobile phone or other device when you are on the Internet) (“Device Identifier”) for any computer, mobile phone, tablet or other device (any of which is referred to herein as a “Device”) used to access the Websites.
● PROFILE INFORMATION includes your username and password, purchases or orders placed by you (applicable if any orders have been placed), your interests, preferences, product reviews and survey responses.
USER DATA includes information about how you use our websites, products and services, including all areas of our websites that you visit or use and the time of day you visited the websites, among other information.
MARKETING AND COMMUNICATIONS INFORMATION includes your preferences in receiving marketing from us and our third parties and your communication preferences.
LOCATION INFORMATION includes information about your location using a variety of technologies, such as GPS, IP address and connected or nearby Wi-Fi networks.
USER CONTENT INFORMATION includes text (including questions, comments and suggestions), images, audio, videos or other content (collectively, “User Content”) that you share by participating and posting content publicly in reviews, interactive features or other communication functionality (“Community Features”).
We also collect, use and share AGGREGATE INFORMATION such as statistical or demographic information for any purpose. Aggregate Information may be derived from your Personal Information but is not considered Personal Information in law as this information does not directly or indirectly disclose your Personal Information.
indirectly your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Website. However, if we combine or connect Aggregate Information with your Personal Information so that it can directly or indirectly identify you, we treat the combined information as Personal Information that will be used in accordance with this Privacy Policy. We do not collect any SPECIAL CATEGORY of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information and genetic and biometric data).
We also do not collect information about criminal convictions and offences.
III. HOW WE COLLECT YOUR PERSONAL INFORMATION
We use different methods to collect information from and about you, including through:
● DIRECT INTERACTIONS. You may give us your identity, demographic, contact, financial, profile, or marketing and communications information by filling out forms or writing to us by mail, phone, email or otherwise. This includes Personal Information you provide when you:
● purchase our products or services;
● create an account on our websites;
● subscribe to emails or newsletters;
● request services or other information;
● participate in a contest, promotion or survey; or
● give us information about products, services or the websites.
● AUTOMATED TECHNOLOGIES OR INTERACTIONS.
As you browse the Websites, we may automatically collect technical, usage and location information about your equipment, browsing actions and patterns. We collect this Personal Information through the use of cookies, pixel tags, embedded scripts and other similar technologies. We may also receive Technical Information about you if you visit other websites that use our cookies].
● COOKIES – Cookies are small data files that a website sends to your Device while you are viewing the website that are stored on your Device. Cookies can be used for many purposes, including to monitor website usage, to customize content specific to your interests, to ensure you do not see the same ad repeatedly, to speed up your searches and purchases, and to recognize you when you return to our Websites and/or store your username and password so you do not have to re-enter it each time you visit the
Websites. You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you choose to disable cookies on your Device, some features of the Websites or our content may not function properly.
● PIXEL TAG – Pixel Tags (also known as clear GIFs, 1×1 GIFs Web beacons, or Web bugs) are small graphic images or other web programming code that may be embedded on the Websites and in our email messages. Unlike Cookies, which are stored on a user’s Device, Pixel Tags are embedded invisibly on web pages. Pixel Tags may be invisible to you, but any electronic image or other web programming code embedded on a web page or in an email can act as a pixel tag. Pixel tags or similar technologies may be used for a variety of purposes, including, without limitation, counting visitors to websites, monitoring how users navigate websites, counting how many emails sent were actually opened, or counting how many particular articles or links were actually viewed.
● EMBEDDED GRAPHICS – EMBEDDED GRAPHICS are programming code designed to collect information about your interactions with websites, such as the links you click on. The code is temporarily downloaded to your Device from our web server or a third party service provider, and is only active while you are logged into the Websites.
● FLASH LSOS – When we publish videos, third parties may use local shared objects, known as “flash cookies”, to store your preferences for volume control or to personalise certain video features. Flash cookies differ from browser cookies in the amount and type of data and in the way the data is stored. The cookie management tools provided by your browser do not delete flash cookies. For information on how to manage the privacy and storage settings of Flash cookies, please visit
LP/SETTINGS_MANAGER07.HTML.
● COMMUNITY FEATURES. The Websites may provide you with the opportunity to participate and post User Content publicly through reviews, polls, interactive features or other communication features (“Community Features”). We may provide functionality for you to submit or post User Content through Community Features, by linking the Websites to a third party service or otherwise. Please note that certain information, such as your name, may be publicly displayed on the Websites along with your User Content. User Content consisting of uploaded files may contain metadata, which may contain Personal Information or other information about or relating to you. You may wish to
remove metadata from your files before transmitting them to EDconsulting . PLEASE NOTE THAT ANYTHING YOU POST THROUGH THE COMMUNITY FEATURES IS PUBLIC – OTHERS WILL HAVE ACCESS TO YOUR USER CONTENT AND MAY USE IT OR SHARE IT WITH THIRD PARTIES. IF YOU CHOOSE TO VOLUNTARILY DISCLOSE PERSONAL INFORMATION, THAT INFORMATION WILL BE CONSIDERED PUBLIC INFORMATION AND THE PROTECTIONS OF THIS PRIVACY POLICY WILL NOT APPLY. IF YOU SUBMIT USER CONTENT, IT MAY BE POSTED ONLINE OR OFFLINE AT ANY TIME. IN ADDITION, WE MAY USE YOUR USER CONTENT AND ANY EXCERPTS OF YOUR USER CONTENT IN CONNECTION WITH OUR ADVERTISING, MARKETING, PUBLICITY AND PROMOTIONAL ACTIVITIES.
THIRD PARTY OR PUBLICLY AVAILABLE SOURCES. We may receive personal information about you from various third parties. For example, if you are on another website and opt-in to receive information from us, the other website will send us your Contact Information and other information so that we can contact you as requested. We may also supplement the information we collect with outside records from third parties to provide you with the information, services or goods you have requested, to improve our ability to serve you and to tailor our content to you. We may combine the information we receive from these other sources with information we collect through the Websites. In such cases, we will apply this Privacy Policy to the combined information. Examples of third party sources include:
● Technical information from the following parties ○ analytics providers; ○ advertising networks; and ○ search information.
Contact, financial and transactional information from technical, payment and delivery service providers.
Identity and contact information from public sources.
INFORMATION PROVIDED BY OTHER USERS. If you choose to invite a third party to create an account and/or purchase merchandise from us, we will collect the identity and contact information you provide (e.g., name and email address) for you and the third party in order to send you a message and follow up with the third party. We rely on you to obtain such consents from the third party as may be required by law to allow us to collect such information and contact the third party as described in the previous sentence. You or the third party may contact us at info@edconsulting.biz to request removal of this information from our database.
IV. INTERACTIONS WITH THIRD PARTIES
Certain features of the Websites may allow interactions that you initiate between the Websites and a third party site or service (“THIRD PARTY INTERACTIONS”). Examples of Third Party Interactions may include technology that allows you to “like” or “share” content from the Websites on or to other websites or services; transmit content to the Websites from your account on a third party website or service; otherwise connect the Websites to a third party website or service, such as through an application programming interface (API) made available by EDconsulting or a third party; or for users to register for an account and log in through social networking sites such as Facebook and Google (each an “SNS”). By registering or logging in through an SNS, you are allowing the websites to access your information and you are agreeing to the Terms of Use and Privacy Policy of the SNS in the use of those services. We may receive information from SNSs to facilitate your creation of an account with us. Any information we collect from your SNS account may depend on the privacy settings you have with that SNS, so we encourage you to review the privacy and data practices of SNS.
If you choose to use Third Party Interactions, the information you post or provide access to may be publicly displayed on the Websites or by the Social Function provider you use. Similarly, if you post information on a third party platform that references the Websites (for example, by mentioning one of the Websites or using a hashtag associated with one of the Websites in a tweet or status update), your post may be published on our Websites in accordance with the terms of the third party website or service. In addition, both EDconsulting and the third party may have access to certain information about you and your use of the Websites and the third party website or service. In addition, we may receive information about you in connection with other users’ use of the third party’s interactions (for example, we may learn that you are a “friend” or “connection” of the third party or receive other information about you that the other user allows us to receive). The information we collect in connection with interactions with third parties is subject to this Privacy Policy.
Information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices regarding what is visible to others on that third party’s website or service.
V. THIRD PARTY AD SERVERS AND ANALYTICS PROVIDERS; ONLINE TRACKING
EDconsulting works with certain third parties (including network advertisers, advertising agencies and analytics companies) to provide us with information about website traffic, to serve ads, including our ads elsewhere online, and to provide us with information about website usage and the effectiveness of our ads.
These third parties may use Device Identifier and Usage Data to compile reports on user activity. For example, if you clicked on one of our ads that took you to one of our websites, our service provider(s) may tell us which ad you clicked on and where you were viewing the ad. These third parties may set and access their own tracking technologies (including cookies, embedded scripts and pixel tags) and may otherwise collect or have access to your Device Identifier, Usage Data and related information about you. Cookies and pixel tags, including those set by third party network advertisers, may be used, among other things, to target ads, prevent you from seeing the same ads too many times, conduct research on the usefulness of certain ads to you, and help provide analytics. These third parties may also transfer Device Identifier and Usage Data to other third parties where required to do so by law, or where such third parties process analytics information on their behalf. Each of these third parties’ ability to use and share Device Identifier and Usage Data is restricted by their respective Terms of Use and Privacy Policy. By using our Websites, you consent to these third parties processing your data in the manner and for the purposes set out above. For a complete list of third-party analytics services, please contact us at info@edconsulting.biz.
We may share Device Identifier and Usage Data about visitors with third party advertising companies, analytics providers and other providers for similar purposes. While we may use a variety of service providers to perform advertising and analytics services, some of these companies may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for online behavioral advertising.
For additional information on targeted advertising and “opt-out” procedures for NAI members and companies participating in the DAA’s Self-Regulatory Programme, you can visit:
● NAI Opt-Out Tool (for website users): http://www.networkadvertising.org/managing/opt_out.asp http://www.aboutads.info/choices/ DAA Consumer Choice (for website users):
● DAA AppChoices (for mobile app users): http://youradchoices.com/ appchoices
Please note that opting out through these mechanisms does not prevent you from receiving advertising. You will continue to receive generic advertisements while visiting websites and other online
online venues. Some third parties may collect Personal Information about your online activities over time and across different websites.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to the websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, websites currently do not respond or alter their practices when they receive a “Do Not Track” signal from a visitor’s browser. For more information on Do Not Track, you may wish to visit http://www.allaboutdnt.com.
VI. HOW WE USE YOUR PERSONAL INFORMATION
We may use the information we collect about you, including personal information and usage data:
● to provide you with our products and services and related customer service;
● to process your registration and account creation on the Websites, including verifying that your contact information is active and valid;
● to identify you as a user on our system;
● to provide you with information, products or services that you have requested or agreed to receive;
● to provide better administration of our websites and services;
● (if applicable) to process transactions you initiate, process payments and provide accurate billing and shipping;
● (if applicable) to send you administrative email notifications, such as order confirmations, order status updates, security or support and maintenance notices;
● (if applicable) to bill you for EDconsulting products or services;
● respond to your enquiries regarding employment opportunities or other applications;
● to send newsletters, surveys, offers and other promotional materials related to our services and for other EDconsulting marketing purposes;
● to market our products/services, including recommending products/services that may be of interest to you;
● to improve our websites, products and services;
● to present our websites and their content in a way that is appropriate and effective for you and your computer;
● to personalise and tailor your experience on the websites, for example, by displaying content that we think may be of interest to you;
● to improve the quality of the experience when you interact with our Site and Services for internal business purposes;
● for fraud prevention and security, including enforcing our Terms of Service and this Privacy Policy, protecting our privacy, security or property rights and/or those of you or others, and protecting, investigating or deterring fraudulent, harmful, unauthorised, unethical or illegal activities;
● to carry out our obligations and enforce our rights arising from contracts entered into between you and us;
● to notify you about changes to our service;
● to comply with applicable laws, legal requests and legal process, such as responding to subpoenas or requests from government authorities;
● to contact you regarding your use of the Websites and, at our discretion, changes to the policies or functionality of the Websites; and
● to perform other functions as described at the time of collection, with your consent, or as further described in this Privacy Policy. In addition to the above, we may use anonymous data to analyse requests and usage patterns so that we can improve the content of our services and improve navigation on the Websites.
A.EMAIL COMMUNICATIONS
We may use your identity, contact, technical, usage and profile information to form an opinion about what we think you may want or need, or what may be of interest to you. This is how we decide what products, services and offers may be relevant to you. You will receive newsletters or marketing communications from us if you have requested information from us, purchased goods or services from us, or if you have provided us with your details when you entered a competition or registered for a promotion and, in each case, you have consented to receive marketing communications from us at that time.
B.COOKIES
A cookie is a data file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The identifier is sent back to the server each time the browser requests a page from the server. Cookies can be “persistent” or “session” cookies:
a persistent cookie will be stored by a web browser and will be valid until the set expiry date, unless the user deletes it before the expiry date; a session cookie, on the other hand, will expire at the end of the user’s session, when the web browser is closed. Cookies do not generally contain any information that personally identifies a user, but the personal information we store about you may be linked to information stored in and obtained from cookies.
We may use both session cookies and persistent cookies to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Websites more useful to you and to tailor your experience with us to your special interests and needs.
Most browsers allow you to refuse to accept cookies and to delete them. The methods for doing so vary from browser to browser and from version to version. However, you can obtain information on how to block and delete cookies in some commonly used browsers through the following links:
● CHROME: https://support.google.com/chrome/answer/95647?hl=en;
● EDGE: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy;
● FIREFOX: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website- preferences;
● INTERNET EXPLORER: https://support.microsoft.com/en-gb/help/17442/ windows-internet-explorer-delete-manage-cookies;
● OPERA: http://www.opera.com/help/tutorials/security/cookies/; and
● . SAFARI: https://support.apple.com/kb/PH21411.
Please note that blocking all cookies will have a negative impact on the usability of many websites and if you choose to block cookies, you may not be able to use all features of our websites.
VII. DISCLOSURE OF YOUR PERSONAL INFORMATION
We may share non-personally identifiable information, such as aggregated user statistics, at our discretion and without restriction. We may disclose information we have collected about you, including personal information, as disclosed at the time you provided your information, with your consent as described in this privacy policy, or in the following circumstances:
A. INTERNAL THIRD PARTIES
EDconsulting may, and reserves the right to, share your information with any other company that is not currently, but becomes a parent,
subsidiary or affiliate of EDconsulting. You may have the opportunity to receive information and/or marketing offers from EDconsulting and our affiliated businesses, partners and agents. If you agree at that time to receive such communications, your Personal Information will be disclosed to that third party (or parties). For more information, please refer to the Marketing Communications section.
B. THIRD PARTY THIRD PARTY SERVICE PROVIDERS
We may share personal information with third party service providers in connection with the provision of services to, or on behalf of, EDconsulting and the
connection with the provision of services to, or on behalf of, EDconsulting and the Websites, including to conduct quality assurance testing, to facilitate account set-up, to provide technical support, and/or to provide other services to EDconsulting. You acknowledge and agree that your use of the Websites may include your Personal Information being transferred to and stored by our website hosting company in accordance with their privacy policy.
We may also share information when we work with companies, partners or agents to develop a direct relationship with you or in connection with the Referral Programme.
These service providers may store or use your information outside the EU or the United States.
Administrative and legal reasons
We may transfer and disclose information, including personal information, to third parties:
● to comply with a valid legal enquiry, investigation or process such as a search warrant, subpoena, statute or court order, or if in our opinion such disclosure is required by law;
● to obtain or maintain insurance coverage, manage risk, obtain professional advice, or establish, exercise or defend legal claims, whether in legal proceedings or in an administrative or out-of-court proceeding;
● to protect the safety, interests, rights, property or security of EDconsulting, you or any third party; this may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
● to respond to a breach or attempted breach of security of our websites;
● to defend or enforce our legal rights under any of the Terms of Use of the Websites, any policies applicable to the Websites, or any other agreements you may have with EDconsulting;
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● at the request of governmental authorities conducting an investigation.
We may also use Technical Information to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies at our discretion.
Social Networking Sites
As set out in Section IV, our websites and services allow you to post content on SNSs. If you choose to do so, we will provide information to such SNSs in accordance with your choices. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the relevant SNSs. We shall not be responsible for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or the availability of such SNSs; or (iii) your use of any such SNSs.
Community Features
As set forth in Section III, our Websites and Services allow you to post User Content through Community Features. If you choose to use these features, you will be identified by your first name and last initial. Please note that any Personal Information you include in a public area of the Site will be publicly visible. Once publicly displayed, that information can be collected and used by others. We cannot control who reads your postings or what other users may do with the information you voluntarily post, so it is very important that you do not post information such as private contact information that you do not wish to make publicly available. Once you have posted information publicly, although you may edit and remove it from the Site, you may not edit or remove such cached information collected and stored elsewhere by others (e.g., search engines).
We require all third parties to respect the security of your personal information and to provide the same level of privacy protection as required by this Privacy Policy.
C. SHARING BETWEEN EDCONSULTING COMPANIES; BUSINESS TRANSFERS
EDconsulting may also disclose and transfer your personal information: (i) to a subsequent owner, co-owner or operator of the Websites or the applicable database, or of our products or services; (ii) if EDconsulting (or any of its affiliated, parent or subsidiary companies) assigns its rights with respect to
any of your information to a third party; or (iii) in connection with or during the negotiation of a corporate merger, financing consolidation, restructuring, acquisition or dissolution transaction or proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of our business or assets including, without limitation, during the course of any due diligence process. In the event of insolvency, bankruptcy or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business or assets, that company will own the personal information collected by us and will assume the rights and obligations with respect to your personal information as described in this Privacy Policy. These transfers and disclosures may be made without prior notice.
VIII. YOUR CHOICES
You have several choices regarding the use of information on our websites and services:
A. ACCESSING, UPDATING, CORRECTING OR DELETING INFORMATION
You may review, request access to, update, correct or delete your Personal Information by contacting us at info@edconsulting.biz.
You may request deletion of your Personal Information by contacting us and we will use commercially reasonable efforts to accommodate your request, but please note that we may be required to retain such information and not delete it (or retain it for a certain period of time, in which case we will comply with your request for deletion only after we have complied with such requirements). When we delete any information, it will be removed from the active database, but may remain in our records. We may also retain information for fraud prevention or similar purposes. In addition, please note that we may need to delete your user account in order to delete your personal information.
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you contact us to make changes, we will make good faith efforts to make the requested changes to our then-active databases as soon as reasonably possible. Please note, however, that information may persist internally for our administrative purposes and that residual data may remain on backup media or for other reasons.
B. OPTIMISATION
We will only send you direct marketing emails or other similar communications if you opt-in to receive such emails. In the future, if you do not want your email address or other contact information to be used for promotional purposes, you may indicate your opt-out preference.
for promotional purposes, you may indicate your preference to stop receiving further communications from us and you may “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly (see contact information in Section A above). When you opt out of receiving these marketing messages, this will not apply to Personal Information you provide to us as a result of purchasing any service or other transaction and we may send you service-related communications, including notices of any updates to our Terms of Use or Privacy Policy.
C. CHOOSING NOT TO SHARE PERSONAL INFORMATION
You may choose not to provide us with any Personal Information. In such case, you may still be able to access and use some of the Websites; however, you may not be able to access and use those parts of the Websites that require your Personal Information. You may opt out of receiving marketing emails by following the opt-out instructions above or as provided to you in those emails. Please note that we reserve the right to send you certain communications relating to your account or your use of any of the Websites (e.g., administrative and service announcements, shipping notices and order confirmations) and that these transactional account messages may not be affected if you opt out of receiving marketing communications.
Where we need to collect personal information from you by law, or under the terms of a contract we have with you and you do not provide that information when requested, we may not be able to perform the contract we have or are seeking to enter into with you (for example, to provide goods or services to you). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at that time.
D. MARKETING COMMUNICATIONS
We strive to provide you with choices regarding certain uses of personal information, in particular with respect to marketing and advertising. You may opt out of receiving such communications as set out in Section B above.
Please note that you may still receive service-related and other non-marketing communications.
E. OPT-OUT OF INTERACTIONS WITH THIRD PARTIES AND SNS As set forth in Section IV, our websites and services allow you to
interact with or post content to certain third parties and SNSs. If you wish to discontinue these
interactions and connections, please refer to the third party’s or SNS’s privacy settings to determine how you can
to determine how you can adjust our permissions and manage the interactivity between the Services and your social media account.
IX. DATA SECURITY
EDconsulting uses commercially reasonable security measures to safeguard the personal information we collect from loss, misuse and unauthorized access, disclosure, alteration and destruction. However, please note that no system can be completely secure and EDconsulting does not ensure or warrant the security of any information we collect. You use our websites and provide us with your information at your own risk.
We have established procedures to deal with any suspected breach of personal information and will notify you and any applicable regulator of a breach where we are legally obliged to do so.
X. USERS OUTSIDE SPAIN AND INTERNATIONAL TRANSFERS The Websites are hosted and operated in Spain and third party service providers and partners operate in Spain and the United Kingdom.
service providers and partners operate in Spain and other jurisdictions. If you are located outside
Spain, please note that any information you provide to us may be transferred to and processed in Spain and other countries. By using the Websites, or by providing any information to us, you acknowledge and consent to this transfer, processing and storage of your information in countries where privacy laws may be less stringent than those in the country where you reside or are a citizen.
XI. QUESTIONS
If you have any questions or concerns about our privacy policy or practices, please feel free to contact us by email at info@edconsulting.biz.
XII. ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN UNION
A. PERSONAL INFORMATION
References to “Personal Information” in this Privacy Policy are equivalent to “Personal Data” as governed by European data protection law.
B. LEGAL BASES FOR THE PROCESSING OF PERSONAL DATA
We will only use your personal data where we are permitted to do so by law. We will most commonly use your personal information in the following circumstances:
● Where we need to perform obligations relating to a contract to which you are a party or take steps at your request prior to entering into such a contract.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our
Legitimate interests include those relating to the conduct and management of our business to enable us to provide you with the best service/product and the best and safest experience. We ensure that we consider and balance any potential impact on you (both positive and negative) and your rights before processing your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are required or permitted by law to do so). You can find out more about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Where we have to comply with a legal or regulatory obligation.
We do not generally rely on consent as a legal basis for processing your personal information, except in relation to sending you email marketing communications. You have the right to withdraw consent to marketing at any time by contacting us using the contact information provided above.
Below, in tabular form, we have set out a description of the ways in which we plan to use your personal data and the legal bases on which we rely to do so. We have also identified what our legitimate interests are where appropriate. Please note that we may process your personal data for more than one legal ground depending on the specific purpose for which we are using your data. Please contact us if you require details of the specific legal basis on which we are relying to process your personal data.
C. CONTROLLER
This Privacy Policy is issued on behalf of info@edconsulting.biz.
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details below.
D. DATA RETENTION
We will only retain your personal data for as long as is necessary to fulfil the purposes for which we have collected it, including compliance with any legal, accounting or reporting requirements.
In determining the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal requirements.
In some circumstances, you may ask us to delete your data: see the Request for deletion subsection below for more information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without notifying you.
E. CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we have collected it, unless we reasonably consider that we need to use it for another reason and that this is compatible with the original purpose. If you would like an explanation of how processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and explain the lawful basis for allowing us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where required or permitted by law.
F. PERSONAL DATA RIGHTS OF EU RESIDENTS
In certain circumstances, EU residents may have rights under data protection laws in relation to their personal data, as follows:
● REQUEST ACCESS to their personal data (commonly known as a “data subject access request”). This allows you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
● REQUEST CORRECTION of the personal data we hold about you. This allows you to correct any incomplete or inaccurate data we hold about you, although we may need to verify the accuracy of the new data you provide.
● REQUEST ERRORISATION of your personal data. This allows you to ask us to erase or delete personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or erase your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your erasure request for specific legal reasons which will be notified to you, if applicable, at the time of your request.
● OBJECT TO THE PROCESSING of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something in your particular situation that makes you want to object to the processing on this ground as you believe it affects your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we can demonstrate that we have compelling legitimate grounds for processing your information which override your rights and freedoms.
● REQUEST RESTRICTION OF THE PROCESSING OF YOUR PERSONAL DATA. This allows you to ask us to stop processing your personal data in the following cases: a) if you want us to establish the accuracy of the data; b) if our use of the data is unlawful but you do not want us to erase it; c) if you need us to keep the data even if we no longer need it as you need it to establish, exercise or defend legal claims; or d) if you have objected to our use of your data but we need to verify whether we have compelling legitimate grounds to use it.
● REQUEST THE TRANSFER of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used and machine-readable format. Please note that this right only applies to automated information that you initially gave us your consent to use or where we use the information to fulfil a contract with you.
WITHDRAW CONSENT at any time where we rely on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. We will inform you of this at the time you withdraw your consent.
If you wish to exercise any of the above rights, please contact info@edconsulting.biz.
No fee is normally required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to ask you for specific information to help us confirm your identity and secure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who is not entitled to receive it.
right to receive it. We may also contact you to request further information in relation to your request to speed up our response.
Time limit for responding
We try to respond to all legitimate requests within one month. Occasionally it may take longer than one month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you informed.
Complaints to the supervisory authority
EU residents may have the right to lodge a complaint at any time with the supervisory authority for data protection issues. However, we would appreciate the opportunity to address your concerns before you approach the supervisory authority, so please first contact us directly to enable us to