DATA PRIVACY POLICY

We, ESPRIT SAIN Ltd, 185 West Street, Mansfield, Nottinghamshire, NG20 8XL, UK (“ES”), take the protection of your personal data very seriously in conjunction with the use of the company website of www.myespritsain.com (referred to as “website”).

 

Which personal data we process depends on how you use the websites: with this data privacy policy, we provide information about the type, scope and purpose of the personal data we collect, use and process. This data privacy policy also explains your rights to you. The following data protection provisions apply to the use of our website and our online registration service and govern the collection, processing and use of the data.

 

You can use the ES website in a variety of ways. You will receive detailed information on all possible uses in the further course. Overview of possible uses: You can, for instance, visit the website to get general information about services we offer. You can also register to receive regular information via e-mail about ES and our products and solutions. The data is always processed and used in compliance with the General Data Protection Regulation and in accordance with the country-specific data protection provisions applicable to ES.

You can also use the website without providing us or otherwise leaving behind personal data, if you deactivate cookies. Please note that you may not be able to use all of the functions on the website in this case. The website uses cookies to present the online portfolio, makes the website available, for statistical purposes and to analyse the performance of the website. We do not pass on any personal data to the third parties.

 

ES has implemented several technical and organisational measures to handle the processing in order to offer the most consistent protection possible of personal data processed via this website. To protect the security of your data during transmission, we use encryption procedures that meet the current state-of-the-art (i.e. SSL) via HTTPS. Still, Internet-based data transfers can have security gaps, making it impossible to guarantee complete protection. For this reason, you are free to provide us personal information in an alternative manner. For instance, on the telephone. If you use our website or online registration service, you agree to this data protection provision. If you would like more information about the cookies we use, please read the cookies section of this policy.

OVERVIEW

A. WHO IS THE RESPONSIBLE PARTY?

B) WHAT PERSONAL DATA DO WE COLLECT AND HOW DO WE USE IT?

  1. Surfing on our websites
    1.1 Collection of general data and information

1.2 Collection of personal data

  1. Contact options
    3. Download
  2. Email marketing – Newsletter
    5. Google AdWords
    6. Usage of YouTube plugins

7. Third Party Websites
8. Usage of Google Maps

C) WHO RECEIVES OR HAS ACCESS TO YOUR PERSONAL DATA?

  1. Dispatch service providers
  2. Use of service providers

D) WHAT COOKIES DO WE USE?

  1. What are cookies?
  2. What kinds of cookies does LD use?
  3. How can I allow, prohibit and manage cookies?
  4. How do you prevent cookies from being saved?

E) HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

F) WHAT ARE YOUR RIGHTS?

G) HOW CAN YOU CONTACT US?

A) WHO IS THE RESPONSIBLE PARTY?

The responsible party, in accordance with the General Data Protection Regulation, other data protection laws applicable in the European Union and other provisions of a data protection nature, is 

ESPRIT SAIN Ltd. Telephone: +7984001228

Email: info@myespritsain.com
Internet: www.myespritsain.com

That means ES performs and controls the processing of data on the website on its own responsibility. It also means, however, that ES is your point of contact for all questions pertaining to data processing on the website.

You can contact our data protection officer directly at any time if you have any questions concerning our use of your data and person is:

Bosko Popovic, Telephone 07984001228 or email info@myespritsain.com

B) WHAT PERSONAL DATA DO WE COLLECT AND HOW DO WE USE IT?

“Personal data” includes all information that pertains to an identified or identifiable natural person. A natural person is considered identifiable if they can be directly or indirectly identified, in particular by means of an assignment of a designation, such as a name, ID number, location data, online ID, or of one or more special characteristics that express the physical, physiological, genetic, psychological, financial, cultural or social identity of this natural person.

Processing includes any procedure executed with or without the help of automated processes or any such series of procedures in conjunction with personal data such as the collection, recording, organisation, sorting, saving, adjustment or modification, reading out, querying, using, disclosure via transmission, distribution or another form of provision, comparison or linking, restriction, deletion or destruction.

Whether and which personal data we collect, process and utilise (collectively referred to as “processing”) depends on how you use our website:

  1. SURFING ON OUR WEBSITE

 

1.1   Collection of general data and information

 

ES’s website records a variety of general data and information every time you or an automated system goes to the website. This general data and information is saved in the server’s log files. The following may be recorded: (1) browser types and versions, (2) the operating system used by the accessing system, (3) the website from which an accessing system was referred to our website (referrer), (4) the subpages an accessing system can access on our websites, (5) the date and time of the access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information that serves to prevent risks in the event of attacks on our IT systems.

 

When using this general data and information, ES does not draw any conclusions regarding the relevant person. This information is, in fact, required to (1) correctly display the contents of our website and optimise the contents of our website. ES therefore statistically evaluates the data and information collected and evaluates it with the objective of increasing data protection and data security at our company to ultimately ensure the optimum level of protection of the personal data we process. The data in the server log files is stored separately from all personal data provided by a person. The legal basis for data processing is Sec. 6 para. 1 lit. of GDPR. Our justified interest follows from the purposes listed above for data collection. The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. This is the case after seven days at the latest. Further storage is possible. In this case, the IP addresses of the users are deleted or shortened, so that an assignment of the client is no longer possible.

 

1.2   Collection of personal data

 

It is, in principle, possible to visit our website without your personal data being processed if you have denied the use of cookies. You may not be able to use all of the functions on the website in this case. Please read our declaration for information about the use of cookies. We use the navigation information (data about your computer and visit to our website, in particular, your location, the browser you are using, referral source, length of your visit and the pages you opened) to improve your browser use, to personalise the websites and improve the registration services.

 

  1. CONTACT OPTIONS

 

If you use contact forms on our website or otherwise contact us electronically (for instance via email), we will save and process your personal data. You can use this channel to ask us questions about our services, general questions about ES or submit comments. Personal data you voluntarily provide us will be saved for processing purposes or so we can contact you for possible follow-up questions. For this purpose, we process your following details: last name, first name, email address, your message, which you provide us in accordance with your preferences as we can derive them from your query. This personal data will not be passed on to third parties.

 

The data specified and sent to us in the contact form and via email is processed based on Sec. 6 para. 1 lit. f GDPR. The data you entered in the contact form will remain with us until you request they be deleted, revoke your consent to the data being stored or the reason for the data being stored no longer applies (e.g. after your request has been processed). Mandatory statutory provisions, in particular retention periods, remain unaffected.

 

  1. DOWNLOADING CONTENT

 

You can register for our “FOC” (free of charge) registration service to download free self evaluation documents. Our registration service to use personalised services collects the following personal data: last name, first name, email address, which we process for this purpose. Once you have registered with us, you can access content and services we only offer for registered users. We will only collect and save the personal data you have provided us solely for our own purposes.

 

By registering on our websites, the IP address your Internet service provider (ISP) assigns, the date and the time of the registration will be saved. This data will not be passed on to third parties, unless there is a statutory obligation to pass it on or it is passed on for criminal prosecution purposes. To protect the security of your data during transmission, we use encryption procedures that meet the current state-of-the-art (i.e. SSL) via HTTPS.

You have the option to modify or delete the data provided during registration at any time if needed unless prohibited by statutory retention periods. Of course, we will provide you information about the personal data we save about you at any time. We will gladly correct or delete this data upon your request. To contact us regarding this subject, please send an email to info@myespritsain.com using the subject line: FOC Download. Of course, you can also reach us via post.

 

  1. EMAIL MARKETING – NEWSLETTER

You can subscribe to ES’s newsletter via our website. If you have registered for our email newsletter via forms on our website or requested the newsletter via email, we will process your email address, which you provided us, and other provided data to send the newsletter to you. We process this personal data to send you the newsletter with updates about existing and new services from ES and our activities, each in compliance with applicable competition laws. For this purpose, we process the following personal data: first name, last name and email address, which you provide us in accordance with your preferences as we can derive them from your query. The data specified and sent to us during registration is processed based on your consent (Sec. 6 para. 1 lit. a GDPR).

 

You can object to receiving our email newsletter at any time with effect for the future. For the purposes of revoking consent, there is an “unsubscribe” link at the end of every newsletter. There is also the option to unsubscribe from the ES newsletter via an email to info@myespritsain.com, Subject: Unsubscribe from newsletter. Of course, you can also unsubscribe from the email newsletter at any time with effect for the future via post and telephone (please check Contact us page on our website for further information). We will not pass on your data to third parties unless we inform you separately.

 

  1. GOOGLE ADWORDS

 

ES has integrated Google AdWords on our website. Google AdWords is an Internet advertising service that allows advertisers to place advertisements in Google’s search engine. Google AdWords allows advertisers to define specific keywords in advance via which an advertisement can be exclusively displayed in Google’s search engine results if the user calls up a keyword-related search result using the search machine. The operating company of the Google AdWords services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

 

The purpose of Google AdWords is to advertise our website by showing interest-related advertisements in the Google search engine search results. If you get to our websites via a Google advertisement, a conversion cookie will be saved on your computer, laptop or similar device by Google. You can find an explanation about cookies in a latter part of this document. A conversion cookie becomes invalid after thirty days and is not used to identify you personally. Each Google AdWords customer receives a different cookie.

 

Using conversion cookies, we and Google can also track whether a relevant person who got to our website via an AdWords advertisement generated revenue, i.e. whether they purchased goods or cancelled the process. The data and information collected using conversion cookies will be used by Google to create visitor statistics for our websites. We, in turn, use the visitor statistics to determine the total number of users who were referred to us via AdWords advertisements, i.e. the success or failure of the respective AdWords advertisement and optimise our AdWords advertisements for the future. Neither our company nor other Google AdWords advertising customers will receive information from Google that can be used to personally identify the respective person. Conversion cookies are saved on the basis of Art. 6 para. 1 lit. f GDPR. The LD has a justified interest in the analysis of the user behaviour to optimise both its online offer and its advertisements.

 

You can prevent the placement of cookies via the relevant settings in the browser and thus permanently prohibit their use. This can be done via the browser settings which generally deactivate the automatic placement of cookies or you can set your browser settings to block cookies from the domain “googleadservices.com”. Setting the browser settings in this manner also prevents Google from placing a conversion cookie on your IT system. A cookie placed by Google AdWords can also be deleted at any time via the browser or another software programme. Please note that you can not delete the opt-out cookies if you do not want measurement data to be recorded. If you delete all of the cookies in your browser, you will have to use the respective opt-out cookie again. You also have the option to opt out of receiving the interest-based advertisements from Google. To do so you have to open the LINK from your browser and configure the desired settings there. You can find more information and the applicable data protection provisions from Google.

 

  1. USAGE OF YOUTUBE PLUGINS

 

We present videos on our websites using services provided by YouTube. YouTube is operated by YouTube LLC with headquarters at 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is represented by Google Inc. with headquarters at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

 

We use YouTube plugins on our website. When you visit a page which contains such plugins a connection is established with the YouTube servers and the plugin is shown. This provides the YouTube server with information about the pages you have visited on our websites. If you are logged onto YouTube as a member, then YouTube will automatically assign this information to your personal user account. When you activate the plugin (e.g. by clicking the start button of a video), the corresponding information is likewise assigned to your user account. You can prevent the automatic assignment of this information by logging out of your YouTube account and other accounts operated by the companies YouTube LLC and Google Inc. and deleting their respective cookies before logging onto our websites.  For more information about data processing and YouTube (Google) privacy policies, visit HTTPS://POLICIES.GOOGLE.COM/PRIVACY.

 

  1. THIRD-PARTY WEBSITES

 

Our website contains links to external pages whose content is not located on our server. This is because we have a justified interest in enriching and relating our content to others. ES makes no guarantees with regard to such third-party websites and assumes no responsibility with respect to such third-party websites. You should be aware that the owners and operators of such third-party websites may possibly collect, use or disclose personal data in a manner other than that applied by ES. When accessing internet links to third-party websites, you should review the data privacy policies of these third-party websites. You should also be aware of the fact that third-party websites may use cookies. This data protection policy only applies to content stored on our server.

 

  1. USAGE OF GOOGLE MAPS

 

On our website, we may use Google Maps to visually present our location as well as for the generation of route directions. This is a service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (hereinafter “Google”). When you use Google Maps integrated on our websites, Google stores a cookie on your computer via your browser. Your user settings and data, including your IP address, are processed to display our location and create a route direction. By connecting to Google in this way, Google can determine from which website your request has been sent and to which IP address the directions are to be transmitted. We cannot exclude that Google uses servers in the USA. In general, the cookie is not deleted when you close your browser, but expires after a certain period of time, unless you delete it manually beforehand.

 

Based on the certification according to the EU-US privacy shield (EU-US PRIVACY SHIELD FRAMEWORK – PARTICIPANT LIST OF GOOGLE) Google guarantees that the EU’s data protection regulations will also be observed when processing data in the USA.

The legal basis for the processing of data is Sec. 6 para. 1 lit. f GDPR. Our justified interest is the provision of map material for the user of the websites and thus in the optimisation of the functionality of our website. If you do not agree to this processing of your data, it is possible to deactivate the Google Maps service and thus prevent the transfer of data to Google. To do this, you must deactivate the JavaScript function in your browser. However, we would like to point out that in this case you will not be able to use Google Maps or only to a limited extent.

The use of Google Maps and the information obtained via Google Maps is subject to the GOOGLE TERMS OF USE  and the TERMS OF SERVICE FOR GOOGLE MAPS.

Google also provides more information at HTTPS://ADSSETTINGS.GOOGLE.COM/AUTHENTICATED and HTTPS://POLICIES.GOOGLE.COM/PRIVACY.

C) WHAT COOKIES DO WE USE?

 

  1. WHAT ARE COOKIES?

 

We use so called cookies on our website. These are small text files that are downloaded and saved to the device you are using to surf on our website (e.g. a computer or smartphone, collectively referred to as “computer”) when you access a website. By using cookies, ES can provide the users of our website with user-friendly services that wouldn’t be possible without cookies in place, e.g. optimising information.Using cookies, you allow us to analyse the use of our website. When you visit our website for the first time, you will be informed that we use cookies on our website.

 

  1. WHAT KINDS OF COOKIES DOES ES USE?

 

ES uses a variety of cookies on the website. These cookies are used for a variety of purposes. Depending on their purpose, cookies can be generally assigned to one of the following categories:

 

  • Required cookies:

 

These cookies are required to operate the website. They allow you to freely navigate through the site and use the functions you want to use on our website. If you do not permit the use of these cookies, your visit to the site may be limited and not all functions will be available.

 

  • Function cookies

 

These cookies allow us to offer functions and content on the website that is tailored to you because they save your pre settings. For instance, these cookies can be used to offer interactive information such as viewing our product videos. These cookies are saved on the basis of Sec. 6 para. 1 lit. f GDPR. The ES has a justified interest in saving the cookies for the technically smooth and optimised presentation of all services to its users and to optimise the content and advertising on the websites.

 

  • Analysis cookies

 

These cookies collect data about how the site is used, such as which subpages are visited most. These cookies provide ES analytical data about the performance of the site and insights into how ES can improve the site. Google Analytics cookies are saved on the basis of Sec. 6 para. 1 lit. f GDPR. The ES has a justified interest in the analysis of the user behaviour to optimise both its online offer and its advertisements.

 

  1. HOW CAN I ALLOW, PROHIBIT AND MANAGE COOKIES?

 

You can prevent the placement of cookies by our website at any time via the relevant settings in the browser and thus permanently prohibit their use. Already saved cookies can be deleted via your browser or other software programmes at any time. This is possible in all conventional Internet browsers. If you deactivate cookies in your Internet browser, not all of the functions of our website will be fully available to you. You consent to the use of cookies, if you continue surfing on the site after we have notified you of the use of cookies.

Please note that several functions or areas of the site will not be available if your browser does not allow cookies. You can find more information about how to change your browser settings at WWW.ALLABOUTCOOKIES.ORG.

 

  1. HOW DO YOU PREVENT COOKIES FROM BEING SAVED?

 

You can prevent cookies from being saved via your browser’s settings; however, please note that if you do so, you may not be able to fully utilise all of the functions on our website. You can prevent the placement of cookies by our website at any time via the relevant settings in the browser and thus permanently prohibit their use. Setting the browser settings in this manner also prevents Google from placing a cookie on your IT system. A cookie placed by Google Analytics can also be deleted at any time via the browser or another software program. You also have the option of objecting to the collection of the data generated by Google Analytics cookies related to the use of this website (including your IP address) and the processing of this data by Google and prevent this from occurring. To do this, you have to download and install a browser add-on:

LINK: BROWSER ADD-ON TO DEACTIVATE GOOGLE ANALYTICS

 

This browser add-on notifies Google Analytics via JavaScript that no data and information about visits to websites may be transmitted to Google Analytics. Google will consider the installation of the browser add-on an objection. If the IT system you are using is later deleted, formatted or reinstalled, the browser add-on has to be reinstalled to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by you or another person within your sphere of influence, the browser add-ons can be reinstalled or reactivated.

In addition to or as an alternative to the browser add-on, you can prevent Google Analytics tracking on our websites by clicking on the following link:

DEACTIVATE GOOGLE ANALYTICS

An opt-out cookie will be installed on your device. This will prevent Google Analytics from collecting data for this website and this browser as long as the cookie is installed in your browser. You can find more information and the applicable data protection provisions from Google at HTTPS://POLICIES.GOOGLE.COM/PRIVACY/ and at HTTPS://WWW.GOOGLE.COM/ANALYTICS/TERMS/GB.HTML. Google Analytics is explained in more detail at HTTPS://WWW.GOOGLE.COM/INTL/GB/ANALYTICS.

D) HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

We follow the principles of data avoidance and data minimisation. We therefore only save your personal data as long as it is required to achieve the objective specified here or as is required by the European bodies issuing guidelines and directives or another legislative body in laws or regulations to which ES is subject. Once the purpose no longer applies or these periods are over, the relevant data is routinely blocked or deleted in accordance with the relevant statutory regulations.

E) WHAT ARE YOUR RIGHTS?

OVERVIEW OF YOUR RIGHTS:

  • Right to information/confirmation
  • Right of access by the data subject
  • Right to rectification
  • Right to erasure (right to be forgotten)
  • Right to restriction of processing
  • Right to object
  • Right to receive a notification obligation regarding rectification or erasure of personal data or restriction of processing
  • Right to data portability
  • Right to not be subject to an automated individual decision-making, including profiling
  • Right to object a data protection-related consent declaration
  • Right to lodge a complaint with a supervisory authority

     

RIGHT TO CONFIRMATION/INFORMATION AND ACCESS ACCORDING TO SEC. 15 GDPR. You have the right to demand a confirmation from us regarding whether we are processing personal data pertaining you. You can also receive information about the saved personal data pertaining to you and receive a copy free of charge. This includes the processing purpose and how long your data will presumably be stored and where we obtained your data. You also have the right to receive the data in a structured, conventional and machine-readable format. RIGHT TO RECTIFICATION, ERASURE (RIGHT TO BE FORGOTTEN), RESTRICTION OF PROCESSING AND OBJECT ACCORDING TO SEC. 16, 17, 18 AND 21 GDPR

 

You also have the right to mend incorrect personal data or, with the exception of the mandatory data storage for the purpose of processing the order or fulfilling a legal obligation to which ES is subject, block or delete your personal data. You also have the right to demand the limitation of the processing if this is not required to fulfil the contract or to object to the processing. RIGHT TO DATA PORTABILITY ACCORDING TO SEC. 20 GDPR

You have the right to have the data we process automatically on the basis of your consent declaration or to fulfil a contract surrendered to you or a third party in a conventional, machine-readable format. If you demand a direct transmission of the data to another responsible party, this will only be done if technically feasible. Right to not be subject to an automated individual decision-making, including profiling according to Sec. 22 GDPR

Under certain circumstances, you can continue to assert your rights with respect to automated decisions, meaning not being subject to a differentiation based exclusively on automated processing, including profiling. RIGHT TO OBJECT A DATA PROTECTION CONSENT DECLARATION ACCORDING TO SEC. 21 GDPR. Many data processing procedures are only possible with your express consent. You can revoke already issued consent declarations at any time. An informal email to us is sufficient. The legality of the data processing procedures prior to the revocation remains unaffected by the revocation. We must immediately initiate and execute all rights. If you wish to assert your rights, you can contact our data protection officer. To do so, use the ES contact information stated below.

F) HOW CAN YOU CONTACT US?

If you have questions regarding data protection, please write us an email or contact our data protection officer directly: Bosko Popovic, 185 West Street, Mansfield, Nottinghamshire, NG20 8XL United Kingdom. We reserve the right to occasionally amend this data protection declaration, so it always complies with the current statutory requirements or to implement changes to our services in the data protection declaration, e.g. when introducing new services. If you visit the site again, the new data protection declaration will apply. Please regularly check if there is a new version. The date of the last amendment to this document is shown at the bottom of this page.

 

Last amended on: June 2018