Last updated 6th April 2020
Cinergy Technology Limited trading as ‘Gatekeeper’ (referred to in this policy as “Gatekeeper”, "We", "Us", "Our") takes seriously the confidentiality of the personal data of Gatekeeper customers ("You", "Your"). Please contact Gatekeeper if You have any questions on this policy.
For the purpose of the Data Protection Law, the data controller is Gatekeeper, a trading name of Cinergy Technology Limited, a company registered in Jersey, with company number: 111769, having its registered office at Cinergy House, 1 Boyne Terrace, St Helier, Jersey, JE2 3WA.
Legal Basis for Processing
We collect and use the personal data described below in order to provide you with access to our Site in a reliable and secure manner. We also collect and use personal data:
- For Our legitimate business needs.
- To fulfil Our contractual obligations to You.
- To comply with Our legal obligations.
To the extent We process Your personal data for any other purposes, We ask for Your consent in advance or require that Our partners obtain such consent.
This section explains what cookies are, how Gatekeeper use them and how You can exercise Your choices about them.
What are cookies?
Cookies are small text files that are placed on Your computer, laptop or device by websites that You visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.
Cookies can be “persistent” or “session” cookies. Gatekeeper use persistent cookies and session cookies on the Site.
A persistent cookie is stored on a user’s device in between browser sessions which allows the preferences or actions of a user across a website (or in some cases across different websites) to be remembered. Persistent cookies may be used for a variety of purposes including remembering preferences and choices when using a website. For example, Gatekeeper use persistent cookies to save Your login information for future logins to the Site.
A session cookie allows a website to link Your actions during a browser session. Session cookies are used for a variety of purposes such as remembering data You have entered into forms that You have not submitted. Gatekeeper use session cookies to enable certain features of the Site, to better understand how You interact with the Site and to monitor aggregate usage by users and web traffic routing on the Site. Unlike persistent cookies, session cookies are deleted from Your computer when You log off from a website and then close Your browser.
Which cookies Gatekeeper uses and why
Functionality cookies allow a website to remember information You have entered or choices You make. They are also used to improve how a website functions and performs. These cookies collect information about how visitors use a website, including which pages visitors go to most often and if they receive error messages from certain pages.
Gatekeeper also use third parties to track and analyse usage and volume statistical information from visitors, to further understand how the Site is used and to optimise its performance.
Targeting & Advertising Cookies:
These Cookies may collect non-personal information about Your online behaviour, such as Your IP address and the website You arrived from.
As a result, You may see Gatekeeper advertising on other organisations’ websites. Cookies are then also used to determine if You have interacted with any of Gatekeeper’s advertising or other messaging, such as emails.
Social Media Features and Single Sign-on
A website may use social media features, such as the Facebook “like” button (“Social Media Features”). These features may collect Your IP address and which page You are visiting on a website, and may set a cookie to enable the feature to function properly. You may be given the option by such Social Media Features to post information about Your activities on a Company’s website to a profile page of Yours that is provided by a third party social media network in order to share with others within Your network. Social Media Features are either hosted by a third party or hosted directly on a Company’s website. Your interactions with these features are governed by the privacy and cookies policies of the company providing the relevant Social Media Features.
Gatekeeper also allows You to log in to the Gatekeeper application using sign-in services such as Google. These services will authenticate Your identity and provide You the option to share certain personal information with Gatekeeper such as Your name and email address to pre-populate the Gatekeeper sign-up form.
Your choices regarding cookies
You can set up Your browser options, to stop Your computer accepting cookies or to prompt You before accepting a cookie from the websites You visit. If You do not accept cookies, however, You may not be able to use the whole of the Site or all functionality of the services.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org , http://www.youronlinechoices.eu/ or http://preferences.truste.com/
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
Information provided or collected by Gatekeeper
Information You provide directly to Gatekeeper
How Gatekeeper collect: When You visit the Site, You may complete forms to request information, to request contact from Gatekeeper and/or book a demonstration of the Services Gatekeeper provide. When You do this, You may provide Gatekeeper with data such as Your name, email address, phone number, job title and company name.
Information Gatekeeper collects about You
How Gatekeeper collect: Each time You visit the Site Gatekeeper may automatically collect and process information about Your visit to the Site. Gatekeeper may collect information that reports on and analyses Your use of the Site to measure the effectiveness of the Site, marketing efforts and to identify areas for improvement. Gatekeeper may collect technical information as You navigate through the Site, including the Internet protocol (IP) address used to connect Your computer to the Internet, Your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time), products You viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from a page and contact details used to call the Gatekeeper customer service number.
Gatekeeper may collect profiling information to track You online or via smart devices, to derive information from combining other data sets or using algorithms to analyse a variety of data, such as social media, location data and records of purchases.
Categories of personal data Gatekeeper may collect:
Personal data such as Your name, e-mail address, phone number
Location data or online identifiers such Internet protocol (IP) address, cookies.
Information Gatekeeper receives from other sources
How Gatekeeper collect or receive: Gatekeeper may receive information about You from other websites Gatekeeper operate or other services Gatekeeper provide. In this case Gatekeeper will have informed You when Gatekeeper collected that data that it may be shared internally and combined with data collected on this Site.
Gatekeeper may receive information about You from third parties (including, for example, business partners, affiliates or sub-contractors who provide technical, payment or delivery services, advertising networks, analytics providers, search information providers or credit reference agencies).
Categories of personal data Gatekeeper may collect or receive: Gatekeeper may collect or receive Your name, address, e-mail address and phone number, financial and credit card information, location, computer specification, personal description and photograph.
Uses made of information
Gatekeeper use information held about You for the following purposes:
Information You provide directly to Gatekeeper. Gatekeeper will use this information:
- To improve the Site.
- To diagnose and resolve technical problems with the Site.
- To improve customer service.
- To personalise Your user experience.
- To process payments for use of Gatekeeper’s services.
- To inform You of promotions, contests, surveys, or Site features.
- To carry out Gatekeeper’s obligations and enforce Gatekeeper’s rights arising from any contracts entered into between You and Gatekeeper.
- To provide You with the information, products and services that You request from Gatekeeper. For example to send You information and updates about Your order, or to respond to Your inquiries, questions and requests.
- To provide You with information about products and services Gatekeeper offers that are similar to those that You have already purchased or enquired about.
- To allow You to participate in interactive features of the Site, when You choose to do so.
- To provide You, or permit selected third parties to provide You, with information about goods or services Gatekeeper feel may interest You, where you have consented to us doing so.
- To ensure that content from the Site is presented in the most effective manner for You and for Your computer.
Information Gatekeeper collects about You. Gatekeeper will use this information:
- To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To improve the Site and/or to ensure that content is presented in the most effective manner for You and for Your computer.
- To measure or understand the effectiveness of advertising Gatekeeper serve to You and others, and to deliver relevant advertising to You.
- To make suggestions and recommendations to You and other users of the Site about goods or services that may interest You or them.
- For industry analysis, benchmarking, analytics, marketing, and other business purposes.
- To track Your browsing behaviour, such as the pages You visited over time.
Information Gatekeeper receive from other sources. Gatekeeper may combine information it receives from other sources with information You provide directly to Gatekeeper and information Gatekeeper collect about You. Gatekeeper may use information Gatekeeper receives from other sources and the combined information for any or all of the purposes set out above (depending on the types of information Gatekeeper received).
Disclosure of Your information
To third parties: Gatekeeper may share Your information with the following third parties:
- Business partners, suppliers and sub-contractors for the performance of any contract Gatekeeper enter into with them or You.
- Advertisers and advertising networks that require the information to select and serve relevant adverts to You and others. Gatekeeper do not disclose information about identifiable individuals to Gatekeeper’s advertisers, but Gatekeeper may provide them with aggregate information about Gatekeeper’s users (for example, Gatekeeper may inform them that 250 women aged over 25 have clicked on their advertisement on any given day). Gatekeeper may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, men living in London). Gatekeeper may make use of the information Gatekeeper have collected from You to enable Gatekeeper to comply with Gatekeeper’s advertisers' wishes by displaying their advertisement to that target audience.
- Analytics and search engine providers that assist Gatekeeper in the improvement and optimisation of the Site.
- Credit reference agencies for the purpose of assessing Your credit score where this is a condition of Gatekeeper entering into a contract with You.
- In the event that Gatekeeper sell or buy any business or assets, in which case Gatekeeper may disclose Your information to the prospective seller or buyer of such business or assets.
- If Gatekeeper or substantially all of its assets are acquired by a third party, in which case information held by it about its customers will be one of the transferred assets.
- If Gatekeeper are under a duty to disclose or share Your information in order to comply with any legal obligation, or in order to enforce or apply the terms of any agreement Gatekeeper have with Your and/or any other agreements, or to protect Gatekeeper's rights, property, safety, or the rights of Gatekeeper's customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Gatekeeper do not sell, rent or trade information collected through the Site with third parties for their promotional purposes.
Transfer of information to a third country
You may invite Your users, who can access our Services via the internet. This means that where you chose to post your data within the Services, it could be accessed from anywhere around the world and therefore a transfer of your data outside the EEA or the UK may be deemed to have occurred. You consent to such transfer of your data for and by the way of this purpose.
All information You provide to Gatekeeper is stored on Gatekeeper's secure servers. Any payment transactions will be encrypted using SSL technology. Where Gatekeeper has given You (or where You have chosen) a password which enables You to access certain parts of the Site, You are responsible for keeping this password confidential. Gatekeeper asks You not to share any password with anyone.
The transmission of information via the Internet is not completely secure. Although Gatekeeper will do Gatekeeper's best to protect Your personal data, Gatekeeper cannot guarantee the security of Your personal data transmitted to the Site; any transmission is at Your own risk. Once Gatekeeper have received Your information, Gatekeeper will use strict procedures and security features to try to prevent unauthorised access.
Data Subject Requests: You have the right to request:
- Access to Your personal data.
- Rectification of Your personal data.
- Erasure of Your personal data.
- A restriction on the processing of Your personal data.
- Object to the processing of Your personal data.
- A transfer of Your personal data (data portability).
Lodging a Complaint: You have the right to lodge a complaint in relation to Gatekeeper's collection or use of Your personal data with the applicable data protection authority (“supervisory authority”).
Withdrawing Consent: You have the right to withdraw Your consent to Gatekeeper processing Your personal data, at any time.
If You change your mind in the future and do not wish to have Your e-mail address used for promotional purposes by Gatekeeper, You may withdraw consent by clicking on the “unsubscribe” link located in emails sent by Gatekeeper. Once you do this, You will no longer receive any marketing emails from us. We will however, continue to communicate with You regarding any services You use, billing and support via email.
Gatekeeper will hold Your personal data on Gatekeeper's systems for as long as is necessary for the relevant activity for which it was provided or collected, or as long as is set out in any relevant contract You have with Gatekeeper. If You delete Your account or ask Gatekeeper to do so, then Your personal data will be deleted and the remaining information shall be anonymised for analytical purposes.
Links to other websites and applications
Gatekeeper's intention is to meet the highest standards when collecting and using personal data. For this reason, Gatekeeper take any complaints Gatekeeper receives very seriously. Gatekeeper encourage people to notify Gatekeeper if they think that Gatekeeper's collection or use of their personal data is unfair, misleading or inappropriate.
For individuals located in the EU: your local data protection supervisory authority in the country in which you are located.
For all other individuals: Office of the Information Commissioner, One Liberty Place, Liberty Wharf, La Route De La Liberation, St Helier, JE2 3NY, Jersey.