Privacy Notice

Last updated: 5 November 2024

Introduction

Engager App Online Limited (“EAL”) and its subsidiaries are committed to building your confidence and trust by complying with data protection legislation and best practices that protect your privacy and safeguard your personal information.

This privacy notice (“Privacy Notice”) explains how we collect, use, store, share, and protect your personal information when you visit our website or interact with us over this website. We are registered with the UK Information Commissioner’s Office. Our data protection registration number is ZB327612.

Please take time to read through this Privacy Notice,  our Cookie Notice and other privacy policies we may have implemented for specific services (such as the Engager.app platform) to understand our practices regarding your personal data.

1. What personal information do we collect?

The information that we collect may include, without limitation:

  1. Personal identifiers such as your IP address, name, occupation details and contact details including email and telephone number. 
  2. Occasionally, as part of the functions described in this notice, we may need to process a special category of data. We endeavour to do so only when necessary. 
  3. Device identifiers and connection information such as IP addresses, cookie IDs and your website usage information (including information about how you interact with and use our website, products and services).  
  4. For the purpose of providing you access to the website and the services, we may collect cookies and for more information on how we use cookies and how you can allow or reject cookies, please see our Cookie Notice. 

2. How do we collect your personal information?

We collect data directly in these ways: 

  1. When you Visit our website and enable cookies, pixels or other trackers; or
  2. Subscribe to our newsletters and email notifications; or 
  3. Communicate with us through our website via our ‘Get in Touch’ form or email; or
  4. When you enquire about the demo of our Engager.app platform; and 
  5. Via Website and system management tools.

3. Why do we collect and use your personal information?

We may collect and use your personal data for the following:

  1. To respond to inquiries submitted or to provide products or services to you, our clients, and subscribers.
  2. To enable you to use our services and to participate in any of our programs.
  3. To respond to complaints made by or about you relating to our website, services, and programs.
  4. To keep our website safe, balance its use, protect your privacy.
  5. We may also process your personal information for our legitimate business interests; that is, in order to facilitate the management of our business. This includes the following purposes:
    1. To enhance, modify, personalise or improve our website to the benefit of clients and prospective customers.
    2. To better understand how individuals, interact with our website. To enhance the security of our information systems or identify and prevent fraud.
    3. To conduct research and make statistical analysis and administration, including analysis of trends, tailoring products and services, risk assessment and analysis of costs in relation to our services. We will always ensure that such data is depersonalised or aggregated and can therefore not be personally identifiable to you.

4. Marketing and contact preferences

  1. EAL is committed to respecting your rights in relation to marketing and advertising information from us. We may contact you with information about our products, programmes, events, courses or other resources that may be of interest to you.
  2. You can change or update your marketing communication by clicking the‘Unsubscribe’link included in every email communication we send to you or by contacting us on the contact details provided below.
  3. If you tell us that you no longer wish to receive our direct marketing communications, we will take steps to respect your modified direct marketing preferences and will keep a record of your request to avoid contacting you again in the future with direct marketing content.

5. Your data protection rights and choices

Under Data Protection laws you are entitled to exercise the following rights: 

  1. Access: you have the right to request access to and/or a copy of your personal information. 
  2. Rectification: you have the right to ask us to modify your personal information that you think is inaccurate or incomplete. Please do not hesitate to contact us, so that we can keep your personal information up to date. 
  3. Erasure: you have the right to request the deletion of the personal information we hold about you. Please note that PCL may need to retain some, minimal information in order to respect your request to be excluded from processing. 
  4. Restriction: you have the right to ask us to limit the processing of your personal information. 
  5. Data Portability: you have the right to request that your personal information is provided to you in a machine-readable format. 
  6. Object: you have the right to object to the processing of your personal information if it is based on legitimate or public interest. 
  7. Automated decision-making: you have the right not to be subject to decisions based only on automated processing. 
  8. Consent: you can withdraw your consent at any time by contacting us on the details provided in this Privacy Notice. 
  9. You can choose whether to have marketing communications from us by email, text or telephone. You can update your contact preferences by contacting us using the information in this Privacy Notice. 
  10. To know about the cookies that EAL uses so that you can decide whether to give us permission to accept cookies on your device and provide us access to use such cookies, please refer to our Cookie Notice, for more information. 


To exercise your rights please sent us your request to the address provided in this Notice. If you are not satisfied with our response, you may report to the Information Commissioner’s Office (ICO). Details on how to do so can be found on the ICO’s website at https://ico.org.uk/make-a-complaint/. For more information about your information rights visit www.ico.org.uk.

6. How long do we retain your personal data?

Data acquired about your use of our website or platform depends on the length of the cookie set (see cookie policy) The length of time that we hold your other personal data varies depending on the type of information and its use. We will only keep your personal data for: (i) as long as it is necessary to provide the services and/or products that you have requested; (ii) for the execution of a contract or for such other essential purposes such as, complying with our legal obligations, resolving disputes, investigating disciplinary matters; and (iii) enforcing our agreements. When your personal data is no longer necessary, it will be securely deleted or anonymised. As for how we treat other personal data provided in relation to any specific app or service contracted for please see the Privacy Notice provided in relation to that app or service.

7. Do we share your personal data?

Where necessary and in limited circumstances, we may share your personal information with third parties to the extent permitted by or required by law including to: 

  1. Meet our legal obligations.
  2.  Provide reasonable voluntary cooperation with a relevant police or regulatory investigation or any ongoing or prospective legal proceedings.
  3. In order to establish, exercise or defend our legal rights, including providing information to others for the purposes of fraud prevention and reducing credit risk.


In addition, we make use of expert third party service providers (such as the website host and supporting services) to help us to provide relevant services, expert IT providers helping us with our IT systems, or professional auditors. These third-party service providers may use your personal information in order to provide the agreed service to us, or to you on our behalf. We have contractual agreements in place with third party data providers and we ensure that they are fully compliant with data protection laws.

8. International transfers

If your personal data is being transferred to countries outside the UK or EEA either by us or by our third -party service providers acting on our behalf, EAL shall ensure the necessary organisational and technical measures are in place to meet the legal requirements for  the security and the lawful processing of your personal information.

9. Security

We take appropriate technical and organisational measures to ensure that your personal information is protected, in compliance with our legal obligations. We protect your information using measures that reduce the risks of loss, misuse, unauthorised access, disclosure and alteration.  

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

10. Cookies

Our website uses cookies to estimate our audience size and usage pattern, to store information about your preferences, to customise our website according to your individual interests, to speed up your searches and recognise you when you return to our website. You can control the use of cookies at your individual browser level. Please refer to our Cookie Policy for further information.

11. Privacy Notice Updates

We keep our privacy notice under regular review in order to reflect the changes in law and/or our privacy practices. Please check our website from time to time. In the occasion of significant changes in the way we process your personal data, we will provide a prominent notice on our website.

12. Complaints and queries

We take any complaints we receive seriously. We encourage people to bring it to our attention if they think that our collection, use or storage of personal information is unfair, misleading or inappropriate.

13. How to contact us

We’re always keen to hear from you. If you’re curious about what personal data we hold about you or you have a question or feedback for us on this notice, our websites or services, please get in touch.

As a technology company, we prefer to communicate with you by email – this ensures that you’re put in contact with the right person, in the right location, and in accordance with any regulatory time frames.

You can email us using contact@engager.app.

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