Marketing Data

EasyGates Ltd uses a number of methods to keep previous and potential customers informed about our latest offerings and services.

Email Marketing

EasyGates Ltd maintains several email marketing lists across its various websites.

When you sign up for an email marketing list, we will always make it clear what information is being added to our marketing list.

EasyGates Direct Mailing List

If you opt-in to the EasyGates Direct Mailing List, the following information will be collected and passed on to our email marketing provider SharpSpring:

• Your name
• Your email address
• The following information about your subscription:
• The IP address of the device you used to subscribe
• The time at which you subscribed
• The website or form you signed up on

Depending on how you interact with the EasyGates Direct website, or where you opt in to marketing, the following additional data may be passed on to SharpSpring

• Your Enquiry Details (for example if you opt in while filling in an enquiry form)
• Your Registration Information, Cart Contents and / or Order Details (for example if you opt in while signing up for our store or checking out)

In the future, we may also allow you to select optional "interest categories", which allow you to further narrow down the subjects or products you are interested in.

After you subscribe, SharpSpring may store further information about your interaction with their service, including Device information and Usage data, including but not limited to:

• information about the email client and device you use to open emails
• how you interact with the emails you receive through the SharpSpring service such as which emails opened and whether you clicked any links within the email

You can read more about the data that SharpSpring collects in SharpSpring’s Privacy Policy

We use the Marketing Data you provide to give you regular updates about our latest products, services and offers via email.

The Marketing Data you provide to us for Email Marketing is stored for as long you stay subscribed to our marketing lists.

You can use the following lists to opt-in or opt-out of our marketing list

• Subscribe
• Unsubscribe

Consent: If you opt-in to email marketing, you have given clear consent for us to process your personal data for a specific purpose.

This data is shared with our email marketing provider, SharpSpring. SharpSpring is operated by SharpSpring, Inc.

As well as EasyGates Ltd’s Privacy Policy, your data will also be subject to SharpSpring’s Privacy Policy.

Analytics Data

EasyGates Ltd uses both Google Analytics and SharpSpring to analyse how visitors use our site. Please see the appropriate subsections below to see details for each service.

If you opt-in to Analytics, a cookie is stored on your computer that contains a unique, anonymised ID. This unique ID is a random collection of letters, numbers and symbols, and does not contain any other personally identifiable information which you may provide to us in another context. The client ID is used to differentiate you from other visitors, as well as determine whether you are a first time or returning visitor.

Google Analytics Data

EasyGates Ltd uses Google Analytics to analyse how visitors use our site.

When Google Analytics is enabled, various details about your computer, browser and visit behaviour are passed on to Google. This information may include, but is not limited to:

• Your IP Address
• An estimate of what browser and operating system you are using to visit our site
• What pages you visit and how long for

Your IP address is collected by the Google Analytics service purely for the purpose of determining the approximate geographic location of visits. Google does not share your IP address with us, and only provides us with an anonymous, approximated geographic location. EasyGates Ltd employs Google Analytics’ optional IP Anonymization feature. This feature removes the final set of digits from your IP address before transmitting it to Google, in order to provide a more anonymised and less accurate estimation of your location.

The techniques that Google employ do not collect personal information such as your name, email address, postal address, or telephone number.

We will not link, or seek to link, any of the above information with any personally identifiable information we hold about you.

SharpSpring Analytics Data

EasyGates Ltd uses SharpSpring to analyse how visitors use our site.

When analytics are enabled, various details about your computer, browser and visit behaviour are passed on to SharpSpring. This information may include, but is not limited to:

• Your IP Address
• Preferences and settings: time zone, language, and character size.
• Technical information: type of device, operating system name and version, device manufacturer, browser information (type, version), screen resolution.
• Traffic Data: What pages you visit, how long for and when; referrer URL

Your IP address is collected by the SharpSpring service purely for the purpose of determining the approximate geographic location of visits. SharpSpring does not share your IP address with us, and only provides us with an anonymous, approximated geographic location.

We cannot link any of the data collected by SharpSpring’s analytics tools to a specific individual.

SharpSpring Analytics Data is retained where SharpSpring "have justifiable business need to do so, and/or for as long as it is needed to fulfill the purposes outlined in [their] Privacy Notice, unless a longer retention period is required by law, such as for tax, legal, or accounting purposes."

Please see SharpSpring’s Privacy Policy for more information.

Raw Access Logs

EasyGates Ltd uses various technologies to log traffic across our websites. The majority of this data is anonymous, and is not linked to any IP addresses or other personally identifiable information.

However, in addition to this anonymous data, EasyGates Ltd keeps raw access logs. These raw access logs store the following information about visitors each time a page is accessed:

• IP Address
• User Agent String
• What resource was accessed
• What time it was accessed

These raw logs do not contain any other information. The data transferred between your computer and our servers is not logged, only the page accessed.

EasyGates Ltd keeps these raw logs in order to:

• Ensure network and information security.
• Ensure we can resist malicious actions that compromise the security of our systems and data, such as brute force entry, DDOS and DOS attacks.

Any data that contains personally identifiable information will be kept for no longer than one month.

However, if we believe an IP Address or range of IP addresses to be behind malicious actions that threaten the security and upkeep of our systems, they will be kept on file as long as we believe they may cause us harm, in order to prevent repeat behaviour.

Registration Information

The following information is collected during registration, and can be amended at any time from the account section of the website or prior to checkout:

• Your name and title
• Your company name
• Your contact information, including email address, telephone number and fax number (optional)
• Your geographic information (addresses)

Additional shipping and billing addresses may be added or removed from your address book or amended at any time.

Your Registration Information is used to:

• Create your EasyGates Direct account / log in, which can be logged into again in future to make additional purchases.
• Allow us to contact you regarding any issues with your order (only if you order or attempt to order from us, see Order Details section for more information)
• To inform you of new products, offers and other promotions via email (only when opted into marketing communications)

Your Registration Information is stored on our website database indefinitely (in order to allow customers to order again with as little delay and hassle as possible) or until such a time that you ask us to remove your account. If you request removal of your Registration Information, it will be retained for up to seven additional days (after it is removed from our live / primary data source) in our regular backups. See the Backed up Data section for more information.

If at any time we choose to systematically delete Registration Information, customers will be contacted beforehand in good time if they meet our criteria for removal. We will provide customers with facilities to keep their account in our system if they so wish.

Notices will be posted on our website informing customers of the time of removal, as well as the criteria we used to determine which accounts will be removed (last order date, last login, etc.).

• If you opt-in to marketing communications, your Registration Information will be passed onto our email marketing provider, SharpSpring (as detailed in the Marketing Data section). SharpSpring is operated by SharpSpring, Inc.
• When using the “Address Search” field, the postcode you enter is passed on to our address lookup service, PCA Predict. In addition, your IP address is shared with PCA Predict in order to prevent abuse and overuse of this facility. PCA Predict is the trading name and a trademark of GB Group plc. (Company registration number 02415211)
• When attempting to pay for your goods, your Registration Information - in addition to your Order Details (see below for details) - are passed onto our Payment Provider WORLDPAY (UK) LIMITED (Company registration number 07316500). Additionally, if you choose to pay with PayPal, this data will be passed on to PayPal (Europe) S.à r.l. & Cie, S.C.A.
• Registration information will be encrypted and transferred to another server operated by our backup provider on a regular basis, as outlined in the Backed up Data section.

Cart Contents

When adding products to your cart while logged in, the following details are stored in our database and associated with your Registration Information:

• Items in cart
• Quantity of items in cart
• Prices to be paid for items, delivery and VAT
• Any information added to text fields on customisable products.

If you do not log into or sign up for an account when adding products to the cart, this information is not linked to any personally identifiable information.

This data is stored indefinitely for your convenience.

However, if at any time you would like this data to be removed, you can remove the items from your cart or contact us for assistance. If you remove items from your cart, they will be retained for up to seven additional days (after they are removed from our live / primary data source) in our regular backups. See the Backed up Data section for more information.

These details will never be passed onto a third party unless:

• you proceed to the checkout to attempt to complete your order (see Order Details section below); or
• we have your express permission beforehand; or
• you opt-in to marketing communications, (see Marketing Data section below); or
• are required to do so by law (see Introduction section).

Cart contents will be encrypted and transferred to another server operated by our backup provider on a regular basis, as outlined in the Backed up Data section.

Order Details

When you proceed to the checkout page and attempt to create an order, the following details are stored in our database, assigned an Order Number, and associated with your Registration Information and Cart Contents:

• Purchase order number (optional)
• Order comments (optional)
• Finalised prices to be paid for items, delivery and VAT
• Shipping and billing address chosen for this order

The above information is also stored in our database as a failed / incomplete order if:

• you do not complete the order process; or
• you are transferred to our payment provider (WorldPay) but your payment is not successful.

The Order Details we collect at checkout are used in combination with your Registration Information and Cart Contents in order to:

• ensure your items reach you in a timely fashion; and
• allow us to contact you regarding any issues with your order.

In order to comply with the Companies Act 2006, EasyGates Ltd keeps accounting records for 6 years from the end of the last company financial year they relate to, or longer if:

• they show a transaction that covers more than one of the company’s accounting periods; or
• we are otherwise required to by HMRC (for example for compliance check purposes).

After Order Details are removed from our system, they will be retained for up to seven additional days (after they are removed from our live / primary data source) in our regular backups. See the Backed up Data section for more information.

• Consent: By completing the checkout process, you have given clear consent for us to process your personal data for a specific purpose.
• Contract: processing this data is necessary to fulfil our contractual obligations to you

• When attempting to pay for your goods, your Order Details - in addition to your Registration Information (see above for details) - are passed onto our Payment Provider WORLDPAY (UK) LIMITED (Company registration number 07316500). Additionally, if you choose to pay with PayPal, this data will be passed on to PayPal (Europe) S.à r.l. & Cie, S.C.A.
• If you opt-in to marketing communications, your Order Details will be passed onto our email marketing provider, SharpSpring (as detailed in the Marketing Data section). SharpSpring is operated by SharpSpring, Inc.
• Order details will be encrypted and transferred to another server operated by our backup provider on a regular basis, as outlined in the Backed up Data section.

Enquiry Details

EasyGates Ltd. uses enquiry forms across the EasyGates Direct website for a variety of purposes.

The information collected will vary from form to form, but at the very least an enquiry form will collect your name and email address.

Depending on the form, the following information may also be collected and passed on to our internal technical or sales support teams:

• Telephone number
• Fax Number
• Invoice / Order number for queries relating to previous orders
• Enquiry type
• Any information inputted into the message and subject fields

For enquiries sent via our live chat system (whether the system is online or offline), see the Live Chat Data section.

The personally identifiable information we collect when filling out our contact form is used to ensure we can assist you with your enquiry in an efficient manner.

This information will not be used for marketing purposes unless you opt in to our Marketing List.

Our policies for email retention differ depending on the purpose of the email message, as well as the content of each particular message. Enquiries sent through this form will be kept at a minimum for as long as an enquiry or support case is still ongoing.

Emails may be archived for a longer period if we believe it necessary to keep the email as a record of fact (i.e. if we believe a dispute over the nature or timing of events may occur).

At most, email communications that do not need to be archived for any legal reasons (such as for accounting and VAT records, or if we believe an email may be relevant to any upcoming legal proceedings) will be kept for no longer than 2 years.

These details will be passed onto our CRM (customer relationship management) provider SharpSpring. SharpSpring is operated by SharpSpring, Inc

Live Chat Data

Across the EasyGates Direct website, we use a live chat tool called Tawk.to to provide sales and technical support to visitors.

When you opt-in to Live Chat, Tawk.to sets a cookie on your machine containing a random unique identifier.

On Site Behaviour

When you opt-in use Live Chat, the following information about your on-site behaviour is transmitted to our support team:

• What pages you navigate to.
• When you end, maximise or minimise the live chat.
• When you are typing a message

Contact Details and Chat Transcripts

In addition to the information above, we also require you to input the following information before engaging in live chat:

• Name
• Email address

The transcript of your chat is associated with your Contact Details stored in the Tawk.to system.

Offline Messages

If you use the live chat outside of EasyGates Ltd’s opening hours, the chat window will allow you to send us an Offline Message. As well as being stored in the Tawk.to system as a Chat Transcript, your details will be emailed to the EasyGates Support Team. This email will be handled as set out in the Enquiry Details section.

Your On-Site Behaviour is used to help our support staff to better assist you in your query. For example, by being able to what product you are viewing, our support team can give you more responsive and accurate advice.

At your request, we may use your Contact Details to assist you with your enquiry (such as checking whether your trade store account has been approved, or sending you additional materials like programming guides or brochures). If your issue is not solved or your query is not answered at the end of your live chat, we may use your contact details to provide additional support to you.

On Site Behaviour, Contact Details and Chat Transcripts

On the first weekday of each month (excluding Bank Holidays) we will remove all Live Chat Data that was created prior to the beginning of the previous month.

Your data will be held for no longer than two calendar months.

If you would like your data to be removed before it is scheduled to be deleted, please see the Your Data and Your Rights section.

Unique Identifier

The Unique Identifier cookie that the Tawk.to widget sets in your browser is set to expire after six months. If you would like to remove this unique identifier from your browser, please click here to opt-out of Live Chat.

Consent: By opting-in to live chat, you have given clear consent for us to process your personal data for a specific purpose.

If you would like to withdraw your consent to send us further behavioural data (see On Site Behaviour), please click here.

If you would like this information to be permanently removed from the Tawk.to system, please see the Your Data and Your Rights section.

Your Live Chat Data will be shared with our live chat provider, Tawk.to.

We do not hire any third-party support staff. You will be connected to a member of the EasyGates Support Team.

Backed up Data

The following personally identifiable data is backed up to a remote server (separate from our webserver) once per day:

• Registration Information
• Cart Contents
• Order Details

This data is encrypted using military-grade AES encryption standards before transport to the remote server, during transport, and when the data is at rest on the remote server.

A "snapshot" of the data we store is taken once per day. These snapshots are stored on the remote server for up to seven days, depending on their size.

However, this snapshot of data will contain data older than seven days, in accordance with the retention policies outlined above for each type of data.

Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.

Contract: processing this data is necessary to fulfil our contractual obligations to you