Privacy Policy

PRIVACY POLICY – ENGANCHE 10 LIMITED

Last Updated – March 9, 2024

This Privacy Policy (“Policy”) for ENGANCHE 10 LIMITED. (“we,” “us,” or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you register to use our website available at https://www.e10int.com/ or otherwise engage with us in other related ways. Reading this Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Website. If you still have any questions or concerns after reading this Policy, please contact us at tim.davy@e10int.com or via post with the address provided in the “Complaints” section of this Policy.

1. WHAT DATA DO WE COLLECT?

We collect Personal Data that you voluntarily provide to us when you register on the Website. The Personal Data that we collect depends on the context of your interactions with us and the Website, the choices you make, and the features you use. Currently, we collect and process the following information: Your first name, last name, mobile number, email, your location, passport details and credit card details. We may also collect certain information where you voluntarily provide them. They include the sport(s) you’d like to discuss, event(s) you’d like to experience, where you’d like to travel, approximate dates of departure, number of travelers, and desired spend.

This processing will be carried out in accordance with applicable privacy laws and regulations such as the GDPR and the UK Data Protection Act (DPA) 2018, to ensure the confidentiality and security of your Personal Data. We are committed to maintaining the privacy and protection of your information, and any processing will be conducted in compliance with our Privacy Policy and applicable legal requirements.

 

2. HOW DO WE COLLECT YOUR DATA?

The Personal Data we process is provided to us directly by you, so we can contact you in relation to services that you’ve asked us for more information about, that we’re already providing to you or that we’ve provided to you previously.

 

3. HOW DO WE PROCESS YOUR INFORMATION?

3.1. We process your Personal Data for a variety of reasons, depending on how you interact with the Website, including: (i) to facilitate account creation and authentication and otherwise manage user accounts; (ii) to deliver and facilitate delivery of services to the user; (iii) to respond to user inquiries/offer support to users; (iv) to send administrative information to you; (v) to request feedback; (vi) to keep the Website safe and secure, including fraud monitoring and prevention; (vii) to evaluate and improve the Website, products, marketing, and your experience; (viii) to save or protect an individual’s vital interest.

3.2. In addition to the foregoing, we may use and process your information to comply with our legal obligations, respond to lawful requests or court orders, defend our legal rights and enforce our terms and conditions. This includes protecting our rights, safety, and property, as well as the rights, safety, and property of our users or any other third parties. We may aggregate and anonymise your information to create statistical or aggregated data that does not personally identify you. This aggregated and anonymised data may be used for various purposes, such as analysing usage patterns, improving our services, or conducting market research, or sharing with third parties for lawful purposes.

 

4. LEGAL BASES FOR PROCESSING YOUR INFORMATION

The GDPR requires us to explain the valid legal bases we rely on in order to process your Personal Data. As such, we may rely on the following legal bases to process your Personal Data:

4.1. With your consent. We may process your information if you have given us express permission (i.e. consent) to use your Personal Data for a specific purpose e.g for providing access to the Website. You may withdraw your consent at any time by contacting us with the information provided in the “CONTACT US” section below.

4.2. Performance of a Contract. We may process your Personal Data when we believe it is necessary to fulfil our contractual obligations to you, including providing our services or at your request prior to entering into a contract with you.

4.3. Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your Personal Data for some of the purposes described in order to:

  • Send users information about special offers and discounts on our services;
  • Develop and display personalised and relevant advertising content for our users;
  • Analyse how our Services are used so we can improve them to engage and retain users;
  • Support our marketing activities;
  • Diagnose technical problems and/or prevent fraudulent activities; and
  • Understand how our users use our products and services so we can improve user experience.

 

5. HOW WILL WE STORE YOUR PERSONAL INFORMATION?

Your Personal Data is securely stored in our servers in the UK. We will only keep your Personal Data for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. No purpose in this Policy will require us keeping your Personal Data for longer than two (2) years past the termination of the user’s account unless we have a legal basis to do so. When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise such information, or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

 

6. HOW WILL WE USE YOUR DATA?

We collect your Personal Data so that we can: (i) manage your account; (ii) e-mail you with special offers on products and services we think you might like; or (iii) make bookings and payments on your behalf.

 

7. MARKETING AND ADVERTISING

7.1. We may use your Personal Data to send you information about products and services that we believe may be of interest to you. This may include promotional offers, updates, newsletters, and other marketing communications. If you have previously agreed to receive marketing communications from us, you have the right to opt out at any time. You can unsubscribe from our marketing communications by following the instructions provided in the communication itself or by contacting us directly.

7.2. You have the right to withdraw your consent for receiving marketing communications from us at any time. You can exercise this right by contacting us using the contact information provided below. Upon receipt of your request, we will promptly cease sending you marketing communications. Note that this will not affect the validity of the information shared before you opted out.

7.3. We will not share your Personal Data with other third parties for marketing purposes without your explicit consent. Your privacy preferences are important to us, and we will respect your choices regarding the use and disclosure of your Personal Data for marketing purposes.

7.4. You have the right to update your marketing preferences at any time. If you wish to change your preferences regarding the receipt of marketing communications or the sharing of your data for marketing purposes, please contact us using the contact details provided below.

7.5. If you have any questions, concerns, or requests regarding our marketing practices or your privacy preferences, please contact us using the following contact information:

 

8. WHAT ARE YOUR DATA PROTECTION RIGHTS?

8.1 . Under data protection laws, you have rights including:

8.1.1. Your right of access – You have the right to ask us for copies of your Personal Data.

8.1.2. Your right to rectification – You have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

8.1.3. Your right to erasure – You have the right to ask us to erase your Personal Data in certain circumstances.

8.1.4. Your right to restriction of processing – You have the right to ask us to restrict the processing of your Personal Data in certain circumstances.

8.1.5. Your right to object to processing – You have the right to object to the processing of your Personal Data in certain circumstances.

8.1.6. Your right to data portability – You have the right to ask that we transfer the Personal Data you gave us to another organisation, or to you, in certain circumstances.

8.2. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

8.3. Please contact us at tim.davy@e10int.com, +44 7921 351130 and/or 1 West Street, Lewes, East Sussex, BN7 2NZ if you wish to make a request.

 

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

9.1. We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any Personal Data we process.

9.1.1. Privacy Policy: Our Privacy Policy is designed to be transparent, easily accessible, and user-friendly. It provides a clear understanding of the types of data we collect, how we utilise that data, and the rights and choices users have concerning their Personal Data. All user data is processed in strict accordance with this privacy policy.

9.1.2. Data Security: We employ industry-standard security measures to safeguard user data. This includes encryption protocols and access controls that help ensure the confidentiality and integrity of the information entrusted to us.

9.1.3. SSL Encryption: Secure Sockets Layer (SSL) and Transport Layer Security (TLS) certificates are implemented to encrypt the data transmitted between users’ browsers and our web servers. This encryption ensures the secure conveyance of sensitive information, protecting it from unauthorised access during transit.

9.1.4. Strong Password Policies: We enforce stringent password requirements for user accounts, encouraging the use of strong, unique passwords. This practice enhances the overall security of user accounts and reduces the risk of unauthorised access.

9.2. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your Personal Data, transmission of Personal Data to and from our Services is at your own risk. You should only access the Website within a secure environment

DO WE MAKE UPDATES TO THIS POLICY?

From time to time, we may update this Policy indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Policy frequently to be informed of how we are protecting your information.

10. COMPLAINTS

If you have any concerns about our use of your Personal Data, you can make a complaint to us at ENGANCHE 10 Limited to tim.davy@e10int.com, +44 7921 351130 and/or 1 West Street, Lewes, East Sussex, BN7 2NZ. You may also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane Wilmslow Cheshire SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

 

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