Last updated 16 May 2023
Welcome to EBar Initiatives Limited’s privacy notice.
EBar Initiatives Limited (“Company”) respects the privacy of all third parties that it has a relationship with and is committed to managing and protecting personal data in adherence with the data protection principles of the 2018 UK Data Protection Act. This privacy notice will inform you as to how we look after your personal data (in all situations where we collect your data) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
This privacy notice aims to give you information on how the Company collects and processes your personal data through all means such as when you subscribe to the Company’s publications; sign up to receive some of the content on our website; supply services to us, purchase services from us, use our website, including any data you may provide through our website when you sign up, download a guide or publication or take part in a promotion.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
For the purpose of the General Data Protection Regulations (“GDPR”), the data controller is EBar Initiatives Limited of 6th Floor, Union Plaza, Union Wynd, Aberdeen, AB10 1DQ (collectively referred to as the Company, “we”, “us” or “our” in this privacy notice).
We have appointed a data protection manager (DPM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPM using the details set out below.
Email address: nickbeeson@ebar.co.uk
Postal address: eBar Initiatives Ltd, 6th Floor, Union Plaza, Union Wynd, Aberdeen, AB10 1DQ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 16.05.2023
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any information about criminal convictions and offences.
We use different methods to collect data from and about you including through:
You may give us your Identity, Contact and Financial Data when subscribing to the Company’s publications, filling in forms on this website, or by corresponding with us by post, phone, email, and telephone or otherwise. This includes personal data you provide when you:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
The legal ground for processing means that organisations can process your personal information if they;
You have the right to withdraw consent to marketing from eBar Initaitives Limited at any time by contacting us at contactus@ebar.co.uk.
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at contactus@ebar.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
Purpose/Activity: To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy; (b) Asking you to leave a review or take a survey
Type of data: (a) Identity; (b) Contact; (c) Profile; (d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Purpose/Activity: To enable you to partake in a prize draw, competition or complete a survey
Type of data: (a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you; (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) Identity; (b) Contact; (c) Technical
Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); (b) Necessary to comply with a legal obligation
Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data: (a) Identity; (b) Contact; (c) Technical; (d) Usage; (e) Profile
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You will receive marketing communications from us only if you have explicitly requested information from us or purchased services from us or if you provided us with your details when you enquired for further information, entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at contactus@ebar.co.uk at any time.
A cookie is a small data file that certain web sites write to your hard drive when you visit them. The only personal information a cookie can obtain is information a user supplies him or herself. A cookie cannot read data from your hard disk or read cookie files created by other sites. Cookies, however, enhance our web site performance in several ways, including providing a secure way for us to verify your identity during your visit to our web site and personalising your experience on our site, making it more convenient for you. This web site uses the following cookie types so that we can serve you better.
These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) to provide an enhanced, more personal experience. For instance, remembering a choice such as not to be asked again to fill in a questionnaire or user poll, or fulfilling a request by the user such as submitting a comment. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
This site uses:
These cookies collect anonymous information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works. Any data collected is limited to the website operator’s use only, for managing the performance and design of the site. These cookies can be third party cookies but the information must be for the exclusive use of the publisher of the website visited.
This site uses:
Google’s cookies for analytics and for conversion tracking. As follows:
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This cookie is typically written to the browser upon the first visit to our site from that web browser. If the cookie has been deleted by the browser operator, and the browser subsequently visits your site, a new __utma cookie is written with a different unique ID. This cookie is used to determine unique visitors to our site and it is updated with each page view. Additionally, this cookie is provided with a unique ID that Google Analytics uses to ensure both the validity and accessibility of the cookie as an extra security measure. This cookie expires 2 years from set/update.
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This cookie is used to establish and continue a user session on our site. When a user views a page on our site, the Google Analytics code attempts to update this cookie. If it does not find the cookie, a new one is written and a new session is established. Each time a user visits a different page on our site, this cookie is updated to expire in 30 minutes, thus continuing a single session for as long as user activity continues within 30-minute intervals. This cookie expires when a user pauses on a page on our site for longer than 30 minutes.
Google Conversion tracking
The conversion tracking cookie is set on your browser only when you click an ad delivered by Google where the advertiser has opted in to conversion tracking. These cookies expire within 30 days and do not contain information that can identify you personally. If this cookie has not yet expired when you visit certain pages of the advertiser’s website, Google and the advertiser will be able to tell that you clicked the ad and proceeded to that page. Each advertiser gets a different cookie, so no cookie can be tracked across advertiser websites. If you want to disable conversion tracking cookies, you can set your browser to block cookies from the googleadservices.com domain.
DoubleClick tracking
We may, from time to time, use the Google DoubleClick cookie to allow us to implement Google Display Network impression reporting which reports display advertisement impressions, other uses of ad services and interactions with these ad impressions and ad services
We also have implemented Google Analytics Demographics and Interest reporting which reports 3rd-party audience data (such as anonymised age, gender and interests) within Google Analytics. You can manage how Google manages this information and “opt out” from data collection at Google Ads Preferences Manager.
We use the information we obtain from our cookies for the following:
A cookie is classed as being first party if it is set by the site being visited. However, a third party cookie is issued by a different server to that of the domain being visited. It could be used to trigger a banner advert based on the visitor’s viewing habits or for analytical purposes. For example, when visiting a page with content embedded from YouTube, Google or Facebook. These service providers may set their own cookies on your web browser. Such anonymous cookies may be set by that third party to track the success of their application or to customise their application to you.
Targeting cookies are used to deliver adverts more relevant to you and your interests. They collect information about your browsing habits and are linked to services provided by third parties, such as ‘like’ and ‘share’ buttons and advertisements. We may use targeting cookies to send third party partners of eBar Initiatives Limited information on your visit so that they can make our advertising more relevant to you when you visit their websites. Examples of such third party partners would be Meta (Facebook & Instagram) or LinkedIn. Online Targeted Advertising does not result in more ads, rather the ads you see will be more relevant to you.
Should you wish to do so, you can refuse cookies by disabling them in your web browser’s settings. If this is done it is important not to exclude the benign and useful session cookies. Choose an option that rejects all third-party cookies such as Do Not Track (DNT), which can be enabled in your browser. Please note that this may impact on the usability of ours and other websites.
Most browsers are defaulted to accept and maintain cookies and you can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it or not. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Please consult the support documentation for your web browser, which can be found online, for more information.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at contactus@ebar.co.uk.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us at contactus@ebar.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
If you have not been a customer of the company, have not made a transaction or interacted with us in the last 2 years we will remove your details from the database.
If you have previously been a customer of the company, have not made a transaction or interacted with us in the last 5 years we will remove your details from the database.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
By law as holders of special categories of personal data we are under a legal and ethical obligation to maintain records safely and securely. We hold this data for 7 years however where a decision is made to retain records for longer than the period mentioned then this is supported by explicit reason and will be recorded in the records.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on this ICO link for more information about your individual rights; https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out by the ICO, please contact us atcontactus@ebar.co.uk.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at contactus@ebar.co.uk.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
You have the right to:
ALL RIGHTS RESERVED
© EBar Initiatives Ltd 2024
Material from this website may not be used without consent.
A company registered in Scotland (SC543722) at 2 Marischal Square, Broad Street, Aberdeen, AB10 1DQ.
VAT registration 257 227 692. Tel: 0330 179 8101