Effective from October 29th, 2021

 

 

1. Please Read Carefully

EON Group Holdings, Inc. cares deeply about the privacy of its visitors. To that end, this Privacy Policy (“Privacy Policy”) describes how EON Group Holdings, Inc. (“Eon”, “we”, “our”, or “us”), collect, use, and share your Personal Information, as well as an explanation of the data rights you may have in that Personal Information.  This Privacy Policy applies to all visitors, including unregistered visitors (collectively, “visitors”, “users”, “you”, or “your”), and to all EON services, including our websites (including circulardataprotocol.org and any of its subdomains, the “Website”), the Circular Product Data Protocol, and related services (collectively, the “Services”).  This Privacy Policy is not intended to override any rights you may have under other applicable data privacy laws.
Prior to accessing or using our Services, please read this policy and make sure you fully understand our practices in relation to your Personal Information.  If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave and discontinue all use of any of our Services.  If you have any questions or concerns regarding this policy, please contact us at privacy@eongroup.co.
By accessing or using any of our Services, you acknowledge that you have read and consent to this Privacy Policy.

2. What Personal Information Do We Collect

2.1. User Information: To provide you some of our Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”).  We collect Personal Information you provide us, from your use of the Services, and from other sources.  Here are the types of Personal Information we collect about you:
2.1.1. Information you provide us.  When you register for our Services or when you contact us directly by any communication channel, you may provide us Personal Information, such as name, email address, phone number, and information you include in your communications with us that may include Personal Information.
2.1.2 Information we collect when you use the Services.  When you visit, download, and/or use any of our Services (ex. this website), we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.

3. Information we collect from other sources.  We may receive Personal Information about you from third-party sources, such as:

a. security providers , fraud detection and prevention providers for example to help us screen out users associated with fraud;
b. advertising and marketing partners in order to monitor, manage and measure our ad campaigns.
We also collect, use, and share Aggregated Data that may be derived from your Personal Information but is not considered Personal Information under data privacy laws as this data cannot be used directly or indirectly to reveal your identity.  For example, we may aggregate your Platform Usage Data to calculate the percentage of users accessing a specific website feature.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).  Nor do we collect any information about criminal convictions and offenses.

4. Why Do We Collect Personal Information

We use your Personal Information for the following purposes:
To provide and operate the Services;
To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences, and difficulties;
To provide our Users with ongoing assistance and/or technical support;
To be able to contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section 7 below);
To help us to update, expand and analyze our records to identify new subscribers;
To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services;
To provide you with professional assistance, only upon your request;
To enhance our data security and fraud prevention capabilities; and
To comply with any applicable laws and regulations.
We use your Personal Information for the purposes set out in this section where:
Our use of your Personal Information is necessary to perform a contract, to support communications programs you have subscribed to (ex. notices of updates to the protocol), to communicate related services offerings to the protocol, or to provide you technical support;
Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or
Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and their effectiveness by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.

5. How We Share Your Personal Information

We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:
5.1. Third Party Service Providers: EON has partnered with a number of selected service providers, whose services and solutions complement, facilitate, and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”).
EON may share the following categories of Personal Information with Third Party Service Providers for a business purpose:
identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers;
commercial information, for example information regarding products or services purchased, obtained, or considered; or
commercial information that pertains to the business account to which the User has access.
The Personal Information may be shared solely in accordance with this policy.
5.2. Law Enforcement, Legal Requests and Duties: EON may disclose or otherwise allow access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.
5.3. Protecting Rights and Safety: EON may share your Personal Information if we believe in good faith that this will help protect the rights, property or personal safety of EON, any of our Users, any Vendors-of-Users, or any member of the general public, with or without notice to you.
5.4. Connection With a Change in Corporate Control: In addition, should EON undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.
5.5. Upon Your Further Direction: EON may also share your Personal Information with third parties for other purposes upon your further direction or with your explicit approval.

6. Where Do We Store Your Personal Information

6.1. Users’ Personal Information may be stored in data centers located in the United States of America.  We may use other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below).
EON is based in the United States, which is not by default considered by the European Commission to be offering an adequate level of protection for the Personal Information of EU Member State residents.  As such Eon Group Holdings have adopted Binding Corporate Rules which satisfy the requirements for data transfers as defined within GDPR.
EON affiliates and Third-Party Service Providers that store or process your Personal Information on EON’s behalf are contractually committed to keep it protected and secured, in accordance with our GDPR compliant standards, regardless of any lesser legal requirements which may apply in their jurisdiction.
6.2. Transfer of EU Personal data: If you are located in Europe, when we will transfer your Personal Information to the United States or anywhere outside Europe, we will make sure that (i) there is a level of protection deemed adequate by the European Commission or (ii) that the relevant Model Standard Contractual Clauses are in place as can be found within our Binding Corporate Rules.
Among other things, EON will ensure that there is the adequate level of protection or that relevant Model Standard Contractual Clauses are in place for the international transfer of our EU users’ data.

7. Use of Cookies and Other Third-Party Technologies

We and our Third Party Service Providers use cookies and other similar technologies (“Cookies”) in order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience.
You can learn more about how we use cookies and similar technologies and how you can exercise control over them in our Cookie Policy.
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
These technologies are used mostly for stability, security, functionality, performance, and advertising purposes.

8. Communications from EON

8.1. Promotional Messages
We may use your Personal Information to send you promotional content and messages by e-mail and similar forms of communication from EON through such means.  If you do not wish to receive such promotional messages and you have provided your Personal Information, you may notify EON at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
8.2. Service and Billing Messages
EON may also contact you with important information regarding the protocol, or your use thereof.  For example, we may send you a notice (through any of the means available to us) when an update to the protocol has been released; reply to your support communication from you; forward Data Subjects’ Rights requests; or notify you of material changes in our Services.

9. Your Rights in Relation to Your Personal Information

EON agrees that it is imperative that you have control over your Personal Information.  Pursuant to privacy regulations worldwide, EON enables you to request access to, receive a copy of, update, amend, delete, or limit processing of your Personal Information.  Some requested information may be unavailable due to our policy of erasing data that no longer serves a purpose.  
To fulfill our data security commitments to you, we may ask you for additional information in order to confirm your identity and for security purposes before fulfilling your request. We reserve the right to reject a request where permitted or required by law (e.g. if your identity cannot be verified or if you submit an excessive number of requests as outlined under CCPA).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
If you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Vendor-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please email us at privacy@eongroup.co or you can also mail your request to EON Group Holdings, Attn: Data Protection Office, 400 Park Avenue South, New York, NY 10016, USA. We will make reasonable efforts to honor your request within the legally allotted time (unless we require further information from you in order to fulfill your request), subject to legal and other permissible considerations.

10. Additional Information for California, USA Residents

If you are a California, USA resident using the Services, the California Consumer Privacy Act (“CCPA”) may provide you the right to request access to and deletion of your Personal Information.
In order to exercise the right to request access to and deletion of your Personal Information, please see the information above. We do not discriminate based on the exercise of any privacy rights that you might have under this Section.
EON does not sell Personal Information to third parties for the intents and purposes of the CCPA.

11. Questions and Complaints

If you have any questions or concerns about this Privacy Policy, use or disclosure of Personal Information, or if you believe that we have not complied with this Privacy Policy or applicable data protection laws, please contact us – our details are set out at the end of this Privacy Policy.
Our Information Security team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.  We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly and in accordance with applicable law.
You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.

12. Data Retention

We may retain your Personal Information for as long as your account is active, as indicated in this Privacy Policy, or as otherwise needed to provide you with our Services.
We may continue to retain your Personal Information after you deactivate your account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
We maintain a data retention policy which we apply to Personal Information in our care.

13. Security

EON has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic, and procedural measures.  Among other things, we offer HTTPS secure access to most areas on our Services; and the transmission of sensitive information is protected by an industry standard SSL/TLS encrypted connection.  We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
Regardless of the measures and efforts taken by EON, we cannot and do not guarantee the absolute protection and security of your Personal Information or any other information you upload, publish or otherwise share with EON or anyone else.  We encourage you to set strong passwords for any account, and avoid providing us or anyone with any sensitive Personal Information of which you believe its disclosure could cause you substantial or irreparable harm.
Furthermore, because e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
If you have any questions regarding the security of our Services, you are welcome to contact us at privacy@eongroup.co.

14. Third-Party Websites

Our Services may contain links to other websites or services. We are not responsible for such websites’ or services’ privacy practices.  We encourage you to be aware when you leave our Services and to read the privacy statements of each and every website and service you visit before providing your Personal Information.  This Privacy Policy does not apply to such linked third party websites and services.

15. Updates and Interpretation

We may update this Privacy Policy as required by applicable law, and to reflect changes to our Personal Information collection, usage, and storage practices without notice other than by providing updates on the website.  Unless stated otherwise, our most current Privacy Policy applies to all information that we have about you.
Any heading, caption or section title contained herein is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.

16. Contacting Us

If you have any questions about this Privacy Policy or wish to exercise any of your rights as described in Sections 9 or 10 please refer to those sections or contact the Information Security team at privacy@eongroup.co. We will attempt to resolve any complaints regarding the use of your Personal Information in accordance with this Privacy Policy.

You may also contact us by mail at:

Attn: Data Protection Office 
400 Park Avenue South
New York, NY 10016, USA