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PRIVACY POLICY




DATAMARAN PRIVACY POLICY INTRODUCTION

Welcome to Datamaran's privacy notice.

Datamaran respects your privacy and is committed to protecting your personal
data. This privacy notice will inform you as to how we look after your personal
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. Alternatively, you can download a pdf version
of the policy by sending an email to info@datamaran.com. Please also use the
Glossary to understand the meaning of some of the terms used in this privacy
notice.


IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how Datamaran collects and
processes your personal data, including any data you may provide through your
subscription to, or which is collected by, Datamaran® or other Datamaran
products.

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.

Controller

Datamaran Ltd of Woolyard 52-56 Bermondsey Street, London SE1 3UD, United
Kingdom, is the controller and responsible for your personal data (collectively
referred to as "Datamaran", "we", "us" or "our" in this privacy notice).

We have appointed a data privacy manager 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 data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity:    Datamaran Limited

Name or title of data privacy manager:    Jean-Philippe LECOURT - CFO

Email address:    jp@datamaran.com

Postal address:    SE1 3UD

Telephone number:    +44 207 702 9595

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 30 July 2020 and historic versions can be
obtained by contacting us.

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

This 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.


THE DATA WE COLLECT ABOUT YOU

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 as follows:

 * Identity Data may include first name, last name, title, and (for authorised
   users of our products) your username and password.

 * Contact Data may include billing address, country of residence, email address
   and telephone numbers.

 * Technical Data may include internet protocol (IP) address, your login data,
   browser type and version, time zone setting and location, browser plug-in
   types and versions, operating system and platform and other technology on the
   devices you use to access our Website, Datamaran® and other services.

 * Profile Data may include your Twitter username, purchases or orders made by
   you, your interests, preferences, feedback and survey responses.

 * Usage Data may include information about how you use our Website, Datamaran®
   , other products and services, including the full Uniform Resource Locators
   (URL) clickstream to, through and from our services (including date and
   time), page response times, download errors, elements you viewed or words you
   searched for, length of visits, interaction information (such as scrolling,
   clicks, and mouse-overs), analytics such as server monitoring tools to
   monitor the status of our APIs and the type and volume of calls being made to
   them.

 * Marketing and Communications Data includes your preferences in receiving
   marketing from us and our third parties and your communication preferences.

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.

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
product or service you have with us but we will notify you if this is the case
at the time.


HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and 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:

 * apply for our products or services;
 * create an account on our Website or Datamaran®;
 * subscribe to Datamaran® or other services or publications;
 * request marketing to be sent to you; 
 * apply to join a webinar;
 * download material from our Website; or
 * give us some feedback.

Automated technologies or interactions. As you interact with our Website,
Datamaran® or other services, we may automatically collect Technical Data about
your equipment, browsing actions and patterns. We collect this personal data by
using cookies, and other similar technologies. Please see our cookie policy for
further details.

Third parties or publicly available sources. We may receive personal data about
you from various third parties and public sources as set out below:

 * Technical Data from the following parties:

(a) analytics providers such as Google based outside the EU;

 * Identity and Contact Data from our customers (if you are employed or engaged
   by them) who may be based inside or outside the UK and EU to enable you to
   access our products (if the customer has designated you as an authorised
   user) and to enable us to administer customer contracts.

 * Identity and Contact Data from publicly availably sources such as (such as
   SEC filings, sustainability reports, annual shareholder reports, CSR reports,
   Corporate Governance reports, legislation, regulatory guidance, news features
   and, social media content and subscription-based information and/or media
   services.


HOW WE USE YOUR PERSONAL DATA

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:

 * Where we need to perform the contract we are about to enter into or have
   entered into with you.

 * Where it is necessary for our legitimate interests (or those of a third
   party) and your interests and fundamental rights do not override those
   interests.

 * Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on
to process your personal data.

Generally we do not rely on consent as a legal basis for processing your
personal data other than in relation to sending third party direct marketing
communications to you via email. You have the right to withdraw consent to
marketing at any time by contacting us.

Purposes for which we will use your personal data

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.

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 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 in the
table below.

Purpose/Activity Type of Data Lawful basis for processing including basis of
legitimate interest To register you as a new customer contact/authorised user

(a). Identity

(b). Contact

Performance of a contract with you

To manage our relationship with you which will include:

(a). Notifying you about our terms or privacy policy 

(b). Allowing you to download material from our website

(c). allowing you to attend webinars

(a). Identity

(b). Contact

(c). Profile

(d). Marketing and Communications

(a). Necessary to comply a with legal obligation

(b). Performance of a contract with you

(c). Necessary for our legitimate interests (to keep our records updated and to
study how customers use our products/or services

To protect and administer our business, Datamaran® and our website (including
troubleshooting, data analysis, testing, system maintenance, support, reporting
and hosting of data)

(a). Identify

(b). Contact

(c). Technical

(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 group restructuring exercise)

(b). Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or
understand the effectiveness of the advertising we serve to you.

(a). Identify

(b). Contact

(c). Profile

(d). Usage

(e). Marketing and Communications

(f). Technical

Necessary for our legitimate interests (to study how customers use our
product/services, to develop them, to grow our business and to inform our
marketing strategy) To use data and analytics to improve Datamaran®, our
website, products/services, marketing, customer relationships and experiences

(a). Technical

(b). Usage

Necessary for our legitimate interests (to define types of customers for our
product and services, to develop them, to grow our business and to inform our
marketing strategy) To make recommendations and suggestions to you about our
services that may be of interest to you

(a). Identity

(b). Contact

(c). Technical

(d). Usage

(e). Profile

(a). necessary for our legitimate interests (to develop our products/services
and grow our business)

(b). Consent (where you are not an existing customer and have not opted-out of
such communications

Marketing

We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a
view on what we think you may want or need, or what may be of interest to you.
This is how we decide which products, services and offers may be relevant for
you (we call this marketing).

You will receive marketing communications from us if you have requested
information from us or purchased services from us and, in each case in relation
to electronic marketing communications, you have provided opt-in consent to such
marketing (unless you are an existing customer) and not opted out of receiving
that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with
any company outside the Datamaran group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any
time by following the opt-out links on any marketing message sent to you or by
contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. For more information about the cookies we
use, please see our cookie policy.

Change of purpose

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.

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.


DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the
purposes set out in the table in paragraph 4 above.

 * Internal Third Parties as set out in the Glossary.

 * External Third Parties as set out in the Glossary.

Service providers acting as processors based in the USA who provide IT,
marketing and system administration services, namely:

 * Google, Salesforce and HelloSign – for contract management
 * HubSpot and Salesforce– for management of marketing lists
 * Amazon Web Services (AWS) – for the provision of our systems architecture.

 * Third parties to whom we may choose to sell, transfer, or merge parts of our
   business or our assets. Alternatively, we may seek to acquire other
   businesses or merge with them. 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
   privacy notice.

We require all third parties to respect the security of your personal data and
to treat it in accordance with the law. We do not allow our third-party service
providers to use your personal data for their own purposes and only permit them
to process your personal data for specified purposes and in accordance with our
instructions.


INTERNATIONAL TRANSFERS

We may share your personal data within the Datamaran Group. This may involve
transferring your data outside the UK and European Economic Area (EEA).

Many 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:

 * We will only transfer your personal data to countries that have been deemed
   to provide an adequate level of protection for personal data by the European
   Commission. For further details, see European Commission: Adequacy of the
   protection of personal data in non-EU countries.

 * 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 for
   which we might have entered or (as the case may be) will enter into a written
   contract approved by the European Commission which gives personal data the
   same protection it has in Europe. 

Please contact us if you want further information on the specific mechanism used
by us when transferring your personal data out of the EEA.


DATA SECURITY

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.


DATA RETENTION

How long will you use my personal data 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 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.

In some circumstances you can ask us to delete your data: see Request erasure
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.


YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in
relation to your personal data. Please click on the links below to find out more
about these rights:

 * Request access to your personal data.
 * Request correction of your personal data.
 * Request erasure of your personal data.
 * Object to processing of your personal data.
 * Request restriction of processing your personal data.
 * Request transfer of your personal data.
 * Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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.

What we may need from you

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.

Time limit to respond

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.


GLOSSARY

LAWFUL BASIS

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

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.

THIRD PARTIES

Internal Third Parties

Other companies in the Datamaran Group and who are based in Spain, the USA and
The Netherlands.

External Third Parties

 * Professional advisers including lawyers, bankers, auditors and insurers who
   provide consultancy, banking, legal, insurance and accounting services

 * HM Revenue & Customs, regulators and other authorities.

YOUR LEGAL RIGHTS

 * Request Access  to your personal data (commonly known as a "data subject
   access request"). This 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 the personal data that we hold about you. This 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. This 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.

 * Usage Data may include information about how you use our Website, Datamaran®
   , other products and services, including the full Uniform Resource Locators
   (URL) clickstream to, through and from our services (including date and
   time), page response times, download errors, elements you viewed or words you
   searched for, length of visits, interaction information (such as scrolling,
   clicks, and mouse-overs), analytics such as server monitoring tools to
   monitor the status of our APIs and the type and volume of calls being made to
   them.

 * 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 on 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. This 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 the 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.

WEBSITE

Whenever we refer to our Website in this document, we mean
https://datamaran.com, and any associated sub-domains.

 * 
 * 
 * 

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PRIVACY PREFERENCE CENTER

When you visit any website, it may store or retrieve information on your
browser, mostly in the form of cookies. This information might be about you,
your preferences or your device and is mostly used to make the site work as you
expect it to. The information does not usually directly identify you, but it can
give you a more personalized web experience. Because we respect your right to
privacy, you can choose not to allow some types of cookies. Click on the
different category headings to find out more and change our default settings.
However, blocking some types of cookies may impact your experience of the site
and the services we are able to offer.
Allow All


MANAGE CONSENT PREFERENCES

STRICTLY NECESSARY COOKIES

Always Active

These cookies are necessary for the website to function and cannot be switched
off in our systems. They are usually only set in response to actions made by you
which amount to a request for services, such as setting your privacy
preferences, logging in or filling in forms. You can set your browser to block
or alert you about these cookies, but some parts of the site will not then work.
These cookies do not store any personally identifiable information.

PERFORMANCE COOKIES

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our site. They help us to know which pages are the
most and least popular and see how visitors move around the site. All
information these cookies collect is aggregated and therefore anonymous. If you
do not allow these cookies we will not know when you have visited our site, and
will not be able to monitor its performance.

FUNCTIONAL COOKIES

Functional Cookies

These cookies enable the website to provide enhanced functionality and
personalisation. They may be set by us or by third party providers whose
services we have added to our pages. If you do not allow these cookies then some
or all of these services may not function properly.

TARGETING COOKIES

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may
be used by those companies to build a profile of your interests and show you
relevant adverts on other sites. They do not store directly personal
information, but are based on uniquely identifying your browser and internet
device. If you do not allow these cookies, you will experience less targeted
advertising.


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