CORNUCOPIA ENTERTAINMENT LIMITED PRIVACY POLICY
1. INTRODUCTION AND GENERAL TERMS
This Privacy Policy covers the processing of personal data by Cornucopia Entertainment Limited (“Cornucopia Entertainment”, “we”, “us” or “our” in this policy) when providing its services to its clients.
Cornucopia Entertainment is committed to protecting and respecting your privacy. This Privacy Policy explains the basis on which personal data we collect from you or from public sources will be processed by us. Where we decide the purpose or means for which this personal data is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679. You have the right to object to us processing your personal data for direct marketing purposes. Please see paragraph 7 below for more details on how to do this.
This Privacy Policy explains the following:
– What personal data we may collect about you;
– Why our processing is lawful;
– Who we may share your information with;
– How we will use that information;
– Who we may disclose that information to; and
– Your rights regarding the information.
2. WHAT INFORMATION WILL CORNUCOPIA ENTERTAINMENT COLLECT ABOUT ME?
We collect and process the following data, which may include your personal data.
Cornucopia Entertainment’s Website: If you contact us about our services, the forms you complete or the emails you send may include information about you, such as your full name, your email address, the organisation on behalf of whom you are contacting us and your enquiry.
Cornucopia Entertainment Database: Cornucopia Entertainment gathers current and historic business contact data. The data collected about individuals on the Cornucopia Entertainment Database comprises:
– Name;
– Employer Company & Company Details;
– Office Location (Country & City);
– Business Telephone Number;
– Business Email Address;
– Job Title.
We also hold data in respect of your employer company such as its name, alias, size, industry, website and industry. In some case we estimate individuals’ net worth based on publicly available data (for example, the individual’s employment history or if such individual previously sold shares in a company). Where you have moved jobs, we may hold your previous employers and previous titles.
In order to provide certain aspects of its services, Cornucopia Entertainment requires a business email address to be recorded against profiles in its database. Where Cornucopia Entertainment does not have the business email address of a profile, it may generate a business email address based on the email address structure understood to be implemented by the employer company.
We also hold hashed personal email addresses. Hashing is a method of encryption, whereby the email address itself is confiscated, and replaced with a unique reference instead, called a hash. A hash is one of the means used to locate the same individual on social networking. We do not reverse the hash or use the personal email address to contact you.
The majority of the personal data we collect about you comes from publicly available sources such as from business and employment-oriented social networks, recruitment websites and company websites.
Information is also gathered from correspondence with you (by email or phone), from our clients, our affiliate’s services, recruiters and other premium data providers. Cornucopia Entertainment does not seek to collect any non-business-related data such as date of birth, home address, personal email or telephone number and Cornucopia Entertainment does not collect sensitive personal data.
Where our clients use our service to send marketing emails, they may include cookies (or similar technologies) in the emails whereby they can understand whether an email bounced back and was not delivered; whether an email was opened; and whether links in the email were followed.
3. GROUNDS OF PROCESSING
1. Consent
On some occasions, Cornucopia Entertainment processes your data with your consent. Your consent may be obtained by third parties on Cornucopia Entertainment’s behalf. You have the right to withdraw such consent at any time and we will cease to process data after consent is withdrawn.
2. Legitimate interest
Cornucopia Entertainment processes your personal data when it is in our or our clients’ legitimate interest to do so and when these interests are not overridden by your rights. Our and our clients’ legitimate interests include: having information about potential business customers organised in one searchable database, having access to up-to-date and complete information, being able to identify the individual that occupies a certain role within a B2B lead; being able to identify individuals with a certain estimated net worth, enabling clients to only reach out to relevant contacts, being able to generate and contact potential B2B leads in order to undertake forms of B2B marketing, having access to aggregated statistical insights for the purpose of understanding patterns and trends.
3. Necessary because of a legal obligation
Cornucopia Entertainment may process your data to comply with our legal and regulatory obligations e.g. preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
4. Necessary to fulfil an obligation under a contract
Cornucopia Entertainment may process your data where we have a contract with the individual and we need to process their personal data to comply with our obligations under the contract.
4. DATA SHARING
We will share your information with the following:
1. Our companies
Access to personal data within Cornucopia Entertainment and our group of companies is restricted to those individuals who have a need to access the information for our business purposes.
2. Cornucopia Entertainment clients
We may share personal data with our clients as part of offering our services. Cornucopia Entertainment provides limited access to its database. Cornucopia Entertainment clients may use the data to contact individuals on their business telephone, at their business email address, through other electronic mail or through targeted display ads on social networks in order to market products and/or services.
Please note that in making available the data to its clients, Cornucopia Entertainment is processing such data as a processor on behalf of the client, who is acting as the controller. Clients will likely have their own privacy policies and opt-out options, and we recommend you review them. Where Cornucopia Entertainment has made personal data available to its clients, the client privacy policy should list Cornucopia Entertainment as a data source.
3. Suppliers, subcontractors, service providers
We keep your information confidential but may disclose it to suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this privacy policy. However, this is on the basis that they have agreed to safeguard this information.
This includes external third-party service providers, such as accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
4. Government authorities
In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
5. Potential acquirers or investors
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
5. HOW WE WILL USE INFORMATION WE COLLECT ABOUT YOU
Cornucopia Entertainment Website and Cornucopia Entertainment Client Platform: We may process your personal data for the following purposes for Cornucopia Entertainment’s own:
– to administer platform log-ins (where applicable) and to deliver our services to our clients under the agreed terms of service;
– to process your enquiries to reply and provide support, including providing you and/or your organisation with information about the services Cornucopia Entertainment offers;
– to keep you updated via our mailing list with information on news, offers, and updates about Cornucopia Entertainment (see below for how to unsubscribe);
– to compile reports on how visitors use the Cornucopia Entertainment website and improve the website;
– to conduct remarketing for Cornucopia Entertainment, which allows us to show Cornucopia Entertainment ads to people who’ve previously visited our website;
– to conduct advertising on social networks for Cornucopia Entertainment, which means that if you link to one of our social media platforms you may be subject to targeted marketing displaying Cornucopia Entertainment ads via that site.
We work with the third-party advertising networks and social media platforms as set out in our cookie policy here. If you would like to find out more about the way these third parties collect and process your information, please refer to their respective privacy policies.
Cornucopia Entertainment Database: We may use your personal data on the Cornucopia Entertainment Database for the following purposes:
– to build our sales intelligence database to enable our clients to generate and manage sales leads in respect of businesses and high net worth individuals;
– to enable our clients to see relevant display ads on social networks (such as Facebook, LinkedIn and Instagram) and other services;
– to enable our clients to enrich their existing customer relationship management records and receive timely updates of changes;
– to undertake research and compile statistical aggregated reports based on data held in Cornucopia Entertainment’s sales intelligence database;
– to supply data management platforms;
to run our own marketing campaigns and promote our services.
We also process personal data to comply with our necessary legal and regulatory obligations. These include preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
All content: If you send us objectionable content or otherwise behave in a disruptive manner when using our website, we may process personal data included in your messages to respond to and stop such behaviour. Where we reasonably believe you are or may be in breach of the law (for instance, because content you send amounts to harassment or is defamatory), we may use your personal data to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.
Where you receive a marketing email from us, and you would like to be removed from that mailing list please let us know by clicking unsubscribe at the bottom of any marketing email that you receive from us.
YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest.
To make a request, please contact [email protected]
You have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal data held about you on our files (and with any third parties to whom it has been disclosed).
6. OBJECT TO US PROCESSING DATA ABOUT YOU
You can ask us to restrict, stop processing, or delete your personal data if:
– you consented to Cornucopia Entertainment processing the personal data, and have withdrawn that consent;
– Cornucopia Entertainment no longer needs to process that personal data for the reason it was collected;
– Cornucopia Entertainment is processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Cornucopia Entertainment, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
– the personal data was unlawfully processed; or
– you need the personal data to be deleted in order to comply with a legal obligation
7. DATA RETENTION
We will hold your personal data for as long as is necessary for the relevant purpose.
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.
8. CHILDREN
We do not solicit data from or market to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected] . We will delete such information from our files within one hour.
9. SECURITY
Cornucopia Entertainment is committed to keeping your personal data safe and secure from unauthorised access to or unauthorised alterations, disclosure or destruction of information that we hold. We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal data.
Our security measures include:
– hashing and encryption of our services and data;
– regular review of information collection;
– encryption of our services and data;
– restricted access of data to employees, contractors and agents; and
– internal policies setting out our data security.
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
10. CHANGES
We will notify you of any changes to this Privacy Policy by email and/or notice on the website, as appropriate.
11. INTERNATIONAL DATA TRANSFERS
Your personal data which you supply to us is generally stored and kept inside the European Economic Area (EEA). However, due to the nature of our global business and the technologies required, your personal data may be transferred to third-party service providers outside the EEA, in countries where there may be a lower legal level of data protection.
Where we transfer your data outside of the EEA, we transfer the minimum amount of data necessary, anonymise it where possible and we have agreements in place with those parties which include standard data protection clauses to ensure that appropriate safeguards are in place to protect your personal data in accordance with this Privacy Policy and the European levels of data protection. If you would like to find out more about these safeguards, please contact us.
