The following Privacy Policy (the “Policy”) explains how E2E Enterprise Limited (“E2E”, “us”, “our” or “we”) handles personal information about you (the “Customer” or “you”). As a “controller” for the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR“), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (EU) 2003/2426 (collectively, “Data Protection Laws“) we respect your privacy and we are committed to protecting your Personal Data.

E2E takes your privacy very seriously. Please read this Policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data). It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint. 

E2E is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified and which is not already available in the public domain then you can be assured that it will only be used in accordance with this Policy.

As a Member or user of our website, https://e2exchange.com/ (our “Website“), this Policy applies both during your use of the Website and when you apply for Membership through it.

Purpose of this Privacy Policy

This Policy aims to give you information on how E2E collects and processes your personal data. This includes data that you directly provide to us through various channels such as our Website, emails, phone calls, postal correspondence, social media, or face-to-face interactions. It encompasses situations where you join as a Member, engage with us, use our services, provide services to us, or in any other relevant context. It also describes the choices available to you regarding E2E’s use of your personal information, the steps you can take to access this information and, where applicable, to request that we correct or delete it. 

We strongly encourage you to read this Policy in conjunction with any other applicable notices we may provide on specific occasions when collecting or processing your Personal Data. This will ensure that you have a comprehensive understanding of how and why we utilize your data. Please note that this Policy supplements other notices and is not intended to override them.

Your Rights

Requests and objections

You have the right to:

• Request access to your Personal Data, which enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of Personal Data that we hold about you, which enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Data, which enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your Personal Data, which enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request a transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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 the 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.

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 certain circumstances.

Complaints

You have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”), which serves as the supervisory authority for data protection matters in the UK (www.ico.org.uk). However, we kindly request that you allow us the opportunity to address any concerns you may have before contacting the ICO for assistance. Please reach out to us initially should the need arise.

If you would like to access, correct, amend or delete any personal information we have about you, have any questions about this Policy or wish to exercise your legal rights, please contact our Privacy Compliance Officer at: communications@e2exchange.com 

Changes to this Policy and your right to rectification

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.

Personal information we collect:

Personal Data, or personal information, means any information about an individual (“Data Subject”) from which the person can be identified. It does not include data where the identity has been removed (“anonymised data”).

Under various circumstances, we may collect, use, store and transfer different kinds of Personal Data about you. For clarity, categories of Personal Data are grouped together as follows:

1. Identity Data includes data such as first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2. Contact Data includes billing address, delivery address, email address and telephone numbers.
3. Financial Data includes bank account and payment card details.
4. Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
5. Technical Data includes internet protocol (IP) address, website traffic data, your login data, browser type and version, time zone setting and location, pages viewed, referral source, length of visit, clickstream data, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. This kind of data forms the basis of some kinds of cookies (see Cookies section at the end of this Policy).
6. Profile Data includes your username and password, purchases made by you, your interests, preferences, feedback and survey responses.
7. Usage Data includes information about how you use our Website and services. This kind of data forms the basis of some kinds of cookies (see Cookies section at the end of this Policy).
8. Marketing and Communications Data includes your preferences in receiving marketing from us and our Partners and your communication preferences.
9. Personal Data from Publicly Available Sources including information that you have shared on a publicly available platform (e.g. such as a public Facebook page).

This list is not exhaustive and in specific instances we may collect additional data for the purposes set out within this Policy.

We may also collect, use and share Aggregated Data, such as statistical or demographic data. 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 Policy.

Special Category Data

Certain types of data about Data Subjects that are demonstrably sensitive or private, and which could be used in a discriminatory way are viewed as sensitive – and as such, identified as Special Category Data under Data Protection Laws.

When information is collected from a Data Subject, Special Category Data may be collected and processed. Special Category Data is only collected and used where it’s needed to provide you with a product or service you have requested or to comply with our legal obligations.

These kinds of information are to be treated with additional care, in comparison to other forms of Personal Data. 

If You Fail to Provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested; we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with  services). In this case, we may have to cancel a service you have with us – but we will notify you if this is the case at the time.

How we collect personal information

We use different methods to collect Personal Data from you and about you, including:

1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
   1. apply for or use our services;
   2. create an account on our Website;
   3. subscribe to our service, by means of Membership, or publications;
   4. request marketing to be sent to you;
   5. enter a competition, promotion or survey; or
   6. give us some feedback.
2. Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment (e.g. to display web pages properly on your device), browsing actions and patterns (e.g. to inform optimizations to our website). We collect this personal data by using cookies, please see below for further details on how we use cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources. 

We may share and receive personal data about you from various third parties and public sources as set out below:

1. Technical Data from the following parties:
   1. analytics providers such as Google based outside the EU;
   2. advertising networks; and
   3. search information providers.
2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
3. Identity and Contact Data from data brokers or aggregators.

In each case of the above, we will alert you when Data Protection Laws legally requires us to do so.

How we use your personal information

E2E will only use your personal information when the law allows us to. We have set out below, in a table format, 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.

Your Consent

How do you get my consent?

When you provide us with personal information to complete a transaction on our Website, verify your credit card or make a payment, we imply that you consent to our collecting it and using it for that specific reason only.

If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

How do I withdraw my consent?

If you are a recipient of our marketing and communications after you opt-in and you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at communications@e2exchange.com 

Disclosures and Sharing of your Personal Data

We may disclose your personal information if we are enforcing our legal rights, defending legal claims, are required by law to do so or if you violate our Terms and Conditions.

Third-Party Services

We may share your Personal Data with our third-party providers who process your Personal Data as part of the service they offer to us. We implement measures to guarantee that our service providers adhere to legal requirements, utilize your data solely based on our contractual agreement, and maintain its security. In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

Third Party Links

Our Website may contain links to third-party websites, plug-ins, and applications. By clicking on these links or enabling such connections, you may allow third parties to collect or share data about you. Please note that we do not have control over these third-party websites and we cannot be held responsible for their privacy practices. When you navigate away from our Website, we recommend that you review the privacy notice of every website you visit to understand how your data will be handled.

Internet-based Transfers

As the Internet operates on a global scale, utilizing it for the collection and processing of personal data entails the international transfer of data. Regrettably, transmitting information over the Internet is not entirely secure. While we will make every effort to safeguard your Personal Data, we cannot assure the security of data transmitted to our website through third-party networks. Any transmission is undertaken at your own risk. Once we receive your information, we will employ rigorous procedures and security measures to mitigate the risk of unauthorized access.

If we choose to sell, transfer or merge parts of our business or our assets or seek to acquire or merge with other businesses, we may have to share or transfer your Personal Data and/or Special Category Data to the new owners so that we may continue to sell services to you. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Policy.

International Transfer of Information collected.

The majority of Personal Data undergoes processing within the UK and EEA, and as a general practice, we refrain from transferring Personal Data outside the EEA. However, there may be exceptional circumstances where such transfers are necessary. In such cases, we strictly adhere to the conditions outlined in the GDPR to maintain the same level of protection for Data Subjects’ Personal Data when it is transferred to a third country. 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:

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

We take utmost care to ensure that the recipient of the data possesses the capability, willingness, and legal obligation to uphold the standards mandated by the GDPR.

This includes ensuring that the following appropriate measures are in place:

• information security (e.g. encryption, network security, etc.)
• organisational measures (e.g. training and confidentiality measures)
• limiting processing to instructions within a written agreement
• ensuring we can review and audit the Sub-processor’s ability to comply on an ongoing basis
• the application of further proportionate measures in cases where Special Category Personal Data is transferred to countries outside the EEA.

In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So, if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act. Once you leave our stores website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Website’s Terms and Conditions.

Data Security

To protect your personal information, we have implemented appropriate security measures, take reasonable precautions and follow industry best practices to make sure it is not accidentally or inappropriately lost, misused, accessed, disclosed, altered or destroyed.

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards. 

Further, we limit access to your Personal Data to those employees, third-party providers, clinicians and any other third parties who have a business need to access and process the material. In such scenarios, these individuals will handle your Personal Data solely based on our instructions and are bound by confidentiality obligations. We adhere to the principle of “Data Protection by Design” as mandated by the GDPR, ensuring that protection of Personal Data is inherently integrated into all our business activities.

We have implemented procedures to address any potential instances of suspected Personal Data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention – How long will you use my personal information for?

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 information collected, 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.

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.

Cookies

Cookies are small file of letters and numbers that we store in your web browser that allows E2E or a third party to recognise you. Cookies contain information that is transferred to your computer’s hard drive. Cookies can be used to collect, store and share bits of information about your activities across websites. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

Cookies fall under the “Usage” and “Technical” categories of Personal Data described above might be used for the following purposes:

• To enable certain functions
• To provide analytics
• To store your preferences
• To enable ad delivery and behavioural advertising

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our Website or make use of the online payment services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
• Session Cookies. These cookies are used to identify a particular visit to our Website. These cookies expire after a short time, or when you close your web browser after using our Website. We use these cookies to identify you during a single browsing session, such as when you log into our Website.
• Persistent cookies: These kinds of cookies will remain on your devices for a set period of time specified in the cookie. We use these cookies where we need to identify you over a longer period of time. For example, we would use a persistent cookie if you asked that we keep you signed in.

How do third parties use cookies on our Website?

Third party companies (including, for example, advertising networks and analytics companies) generally use cookies to collect user information on an anonymous basis. They may use that information to build a profile of your activities on the E2E and other websites that you’ve visited, over which we have no control. 

What are your cookies options?

If you don’t like the idea of cookies or certain types of cookies, you can change your browser’s settings to block and/or delete cookies that have already been set and to not accept new cookies. To learn more about how to do this, visit the help pages of your browser.

Please note, however, that if you set your browser settings to block all cookies (including essential cookies) or delete cookies, you may not be able to access all or parts of our Website, or experience limited or incomplete functionality.

Age of consent

By using our Website, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.

Changes to privacy policy

E2E reserves the right to review and update this Privacy Policy at any time, for any reason, without notice to you other than posting the amended Privacy Policy to the E2E website, so please review it frequently. 

Changes and clarifications will take effect immediately upon their posting on the Website. 

As a Data Subject you will be notified of any further amendments to this Policy which result in substantial effects to your rights.

Contact us

If you would like to contact a representative at our organisation in relation to: this agreement, your Personal Data, or to assert any of your rights, please contact us:

• Call our offices: +44 (0) 7969 161805
• Email us: communications@e2exchange.com
• Write to us: E2E, 52 Grosvenor Gardens, London, SW1W 0AU 

Our contact will endeavour to get back to you as soon as possible and legally obligated time limits.