The following describes the E-Ticks Private Limited, Inc. ("E-Ticks," the "Company", “we,” “us,” “EagleINSIGHT”, “E-Ticks” or “our”) privacy policy and the manner in which E-Ticks collects, uses, shares and secures the personal information that it collects or receives via its website www.E-Ticks.ie and product website www.eagleinsight.io, any subdomain, other E-Ticks website and mobile applications (collectively, the “Sites”), or through your use of the services we provide to you. It also describes your choices regarding use, access and correction of your personal information.
For purposes of the European Union General Data Protection Regulation (GDPR), E-Ticks is both a data controller and processor of personal information collected by it via our website www.cloudgate.ie including our product websites(i.,e www.eagleinsight.io, www.eticks.io )
Definitions
The data protection declaration of the E-Ticks is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of that data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
CLOUDGATE Pvt Ltd
77, Lower Camden Street,
Dublin 2, Ireland.
What is Personal Information?
As used in this policy, "personal information" means any information that may be used, either alone or in combination with other information, to identify an individual. When we combine any non-personal information with personal information (e.g., technical information, such as the type of browser or operating system that you use), we treat the combined information as personal information.
Collection of Personal Information:
E-Ticks uses your personal information to monitor the performance and improve the quality of its Sites, respond to requests about the Company and its business, provide information about products and services, fulfill customer requests, and for other business purposes and/or to comply with various legal and regulatory obligations. With your consent, E-Ticks may also use your personal information to send you information about its other products and services and for other specified marketing purposes. Unless we obtain your consent to processing of your personal information, E-Ticks processes your personal information either for performance of a contract with you or in circumstances where it has a legitimate interest to do so.
E-Ticks may use information collected through cookies, web beacons, pixels, web server logs and other automated means for purposes such as (a) customizing user visits to the Sites, (b) delivering content tailored to users' interests and the manner in which our users browse the Sites, and (c) managing the Sites and other aspects of its business.
You can change your cookies settings in your browser, however please note that without cookies you may not be able to use all of the features of the Sites. For more information about the cookies we use on the Sites, please click here.
E-Ticks may share your personal information with its affiliates and subsidiaries, and/or with its business partners, in order to respond to customer needs or otherwise provide services to customers as requested. E-Ticks may also, with your consent, engage in joint marketing activities with such third parties and/or disclose personal information to third parties for their own direct marketing purposes. Whereas our data practices and your choice options are described in this Privacy Policy, we encourage you to consult the third party’s privacy policy to ensure that you understand how it intends to use your information and how you may exercise control over it.
E-Ticks may also share your information with its third-party agents who may be acting on its behalf and pursuant to its instructions to assist in our business activities, including, for example, providing notice of an upcoming webinar or tradeshow that may be of interest to the target audience, providing customer service, payment processing or providing storage services.
E-Ticks may disclose your personal information if it is required to do so by law or court order, to enforce or apply its Terms or if it believes in good faith that such release is necessary or appropriate to protect the rights, property, or safety of its company, customers, affiliates or others.
E-Ticks also may share or transfer information, including your personal information, in connection with the sale, transfer, acquisition, merger, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change or ownership or control by E-Ticks or any affiliated company (in each case, whether in whole or in part). When one of these events occurs, E-Ticks will use reasonable efforts to notify users before their personal information is transferred or becomes subject to different privacy practices.
E-Ticks sometimes partners with other companies in order to provide their services via a link on the Site, for example, job applications, social media links and live chat. In those circumstances, the third party partners will have access to the personal information you provide to them via their website, and we do not have any control over how they use that personal information. In order to fully understand how your personal information is used by our partners, please carefully review their applicable privacy policies. Except as set forth herein, E-Ticks does not share your personal information with any third parties.
Other Uses of Personal Information
In addition to the uses described above, E-Ticks will inform individuals of any other intended uses of their personal information at the time such personal information is collected or before such use is implemented including disclosure to third parties.
Data Security and Retention
E-Ticks uses reasonable methods to secure all personal information by a variety of methods, including restricting access to such personal information only to those people who have a legitimate need to know in order to discharge their job responsibilities on behalf of E-Ticks, securing access to the facility where the personal information is stored and the use of technology and physical controls to secure the personal information. E-Ticks is required to disclose personal information in response to lawful requests by public authorities including to meet national security or law enforcement requirements. If you have questions about the security of your personal information, please contact us as described below.
We may retain your personal information for as long as it is needed to fulfill the purposes described in this privacy policy, comply with our legal obligations, resolve disputes or enforce our agreements. Or, we will retain such personal information for so long as we have a lawful basis to process it, as set forth in this policy and with respect to (1) personal information processed by us in connection with our provision of support services, within 90 days after the associated help desk ticket is closed, and (2) all other personal information collected through use of our services, within 30 days after the termination of the applicable contract between you, your company or our customer and us.
Security of Personal Information by Third Parties
E-Ticks will require that all third parties acting on behalf of E-Ticks, and to which personal information is provided, give E-Ticks adequate contractual assurances that they will safeguard all such personal information in a manner consistent with this policy.
Children under the Age of 18
The Sites are not intended for children under the age of 18. Accordingly, we do not intend to collect personal information from anyone we know to be under 18 years of age.
Advertising and Newsletters
We may from time to time allow certain third parties to display advertising on our Sites or to manage our advertising on other sites. These third-party partners may use cookies or similar technologies such as web beacons, script, and pixels in order to provide you advertising based upon your browsing activities and interests. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.
To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:
In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Apple's IDFA or Android's GAID), visit the device manufacturer's current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here: http://www.networkadvertising.org/mobile-choices.
Please note that these settings must be performed on each device (including each web browser on each device) for which you wish to opt-out, and if you clear your cookies or if you use a different browser or device, you will need to renew your opt-out preferences.
We will use your personal information to send you email or newsletters, if you have signed-up to receive them. If you would like to discontinue receiving this information, you may update your email preferences by using the “unsubscribe” link found in emails we send to you, or at your member profile on our website, or by contacting us as described below. You may not opt-out of service-related communications, which are not promotional in nature. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any "Contact Us" request as well as administrative, maintenance and operational emails (for example, in connection with a password reset request).
ACCESS TO YOUR PERSONAL INFORMATION
Upon an individual’s request, E-Ticks will provide reasonable access to any personal information it has about that person. E-Ticks will also take reasonable steps to allow such individuals to correct, change, modify or delete any such personal information that is shown to be incorrect, inaccurate or incomplete. You may ask us to delete the personal information we hold about you, or cease processing such personal information, in certain circumstances. It may not be possible for us to delete or cease processing all of the personal information we hold about you where we have an ongoing relationship with you or where we have a legal basis to retain such personal information.
You may access, correct, or request deletion of your personal information by logging into your account or by contacting us at info@E-Ticks.ie We will respond to your request within a reasonable timeframe.
When we process personal information on the basis that you have consented to such processing, you have the right to withdraw your consent, or ask us to stop or restrict processing the personal information we have about you, at any time by contacting us using the contact information below.
You may also ask us to transfer your personal information to a third party in certain circumstances. If you would like any further information about your rights or how to exercise them, please contact us using the contact information below.
If you are in the European Union, you have the right to make a complaint at any time to the relevant data protection authority in your country. We encourage you to first reach out to us at privacy@eticks.io
Territories and Transfers
Personal information collected by E-Ticks may be stored and processed in your geographic region, in the United States or in other countries in which E-Ticks, or its service providers, maintain facilities or operations. If you are in the European Economic Area, it may be necessary for your personal information to be transferred to, and processed in, other countries including the United States. If we transfer your personal information outside of the European Economic Area to a country or framework not determined by the European Commission and/or the United Kingdom as providing an adequate level of protection for personal information, the transfer will be under an agreement which includes European Union and/or United Kingdom requirements for such transfers, such as standard contractual clauses. The European Commission, and United Kingdom, approved standard contractual clauses are available here.
We do not track users over time and across third party websites to provide targeted advertising. Accordingly, we do not currently respond or take any action with respect to web browser "do not track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about an individual consumer's online activities over time and across third-party web sites or online services.
However, some of our service providers and advertisers may use cookies or other methods to gather information regarding your use of the Sites and may combine the information in these cookies with any personal information about you that they may have. The use of such tracking information by a third party is subject to its privacy policy.
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
the existence of the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the E-Ticks, he or she may, at any time, contact any employee of the controller. An employee of E-Ticks shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee of the E-Ticks will arrange the necessary measures in individual cases.
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the E-Ticks, he or she may at any time contact any employee of the controller. The employee of the E-Ticks will arrange the restriction of the processing.
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact any employee of the E-Ticks.
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
The E-Ticks shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If the E-Ticks processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the E-Ticks to the processing for direct marketing purposes, the E-Ticks will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the E-Ticks for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact any employee of the E-Ticks. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the E-Ticks shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the E-Ticks.
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the E-Ticks.
Before it gets to that situation, please make sure you contact our Data Compliance Officer (Jay Monpara) at privacy@eticks.io if you wish to exercise any of your rights or if you have any questions about the processing of your personal data.
Data protection for applications and the application procedures:
The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this relation is, e.g., a burden of proof in a procedure under the General Equal Treatment Act (AGG).
Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
Period for which the personal data will be stored:
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
Provision of personal data as statutory or contractual requirement:
Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
