Effective from September 17, 2020.
2. Which Personal Information we Collect
2.1. User Information:
To provide you the 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:
1. Information you provide us. When you register for our Services, use any of our Services; provide feedback, and/or when you contact us directly by any communication channel (e.g., EON’s support tickets, emails, etc.), you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with us that may include Personal Information.
2. Information we collect when you use the Services. When you visit, download, and/or use any of our Services, 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. information necessary to create login credentials, verify your identity, or determine your access level from your employer if associated with a paid business account;
b. security providers , fraud detection and prevention providers for example to help us screen out users associated with fraud;
c. 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 offences.
2.2. EON Jobs Applicant Information
We also collect information that is provided to us by EON job candidates (“Applicants”), when they apply to any of the open positions published on our website, by e-mail, or otherwise (as further described in Section 14 below).
3. Why 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 customer assistance and 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 customers;
To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;
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 or to take steps to enter into a contract with you (e.g. to provide you with a platform access, to provide you with our customer assistance and 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 the effectiveness of Eon by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.
4. How We Share 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:
4.1. 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.
4.2. 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.
4.3. 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.
4.4. 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.
4.5. 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.
5. How We Store Personal Information
5.1. Users’ and Vendors-of-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 Group Holdings Inc. is based in the United States, which is not 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 industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
5.2. 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.
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.
7. Communications from EON
7.1. Promotional Messages
We may use your Personal Information to send you promotional content and messages by e-mail, notifications within our platform, and similar forms of communication from Eon through such means. If you do not wish to receive such promotional messages, you may notify EON at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
7.2. Service and Billing Messages
EON may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward Data Subjects’ Rights requests; or notify you of material changes in our Services.
It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer an EON client.
8. 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.
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 rejects 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 are a EON User, and 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 email@example.com 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.
Please note that permanently deleting your EON account erases all of your Personal Information from EON's databases. After completing this process, you can no longer use any of your EON Services, your account and all its data will be removed permanently, and EON will not be able to restore your account or retrieve your data in the future. If you contact our support channels in the future, the system will not recognize your account and support agents will not be able to locate the deleted account.
9. Additional Information for California Residents
If you are a California 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 on the section 8, above. We do not discriminate based on the exercise of any privacy rights that you might have under this Section.
EON does not sell user Personal Information to third parties for the intents and purposes of the CCPA.
EON may collect, store and process certain Personal Information of Vendors of paid Users, solely on our Users’ behalf and at their direction. For such purposes, EON serves and shall be considered as a “Service Provider” and not as the “Business” (as both such capitalized terms are defined in the CCPA. Eon does not and will not sell your customers’ (Vendor) Personal Information.
Users of the Services who are California residents and under 18 years of age may request and obtain removal of content they posted by emailing us at firstname.lastname@example.org. All requests must be labeled “California Removal Request” on the email subject line. All requests must provide a description of the content you want removed and information reasonably sufficient to permit us to locate that content. We do not accept California Removal Requests via postal mail, telephone, or facsimile. We are not responsible for notices that are not labeled or sent properly, and we may not be able to respond if you do not provide adequate information.
10. Questions and Complaints
Our Data Protection 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.
11. Data Retention
We may continue to retain your Personal Information after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Vendors, 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.
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, your Vendors’ 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 your User Account and User Website, 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 email@example.com.
13. Third-Party Websites
14. Job Applications
EON welcomes all qualified Applicants to apply to any of the open positions published on our website, by sending us their contact details and CV (“Applicants Information”) through any other means provided by us.
We understand that privacy and discreetness are crucial to our Applicants, and are committed to keep Applicants’ Personal Information private and use it solely for EON’s internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).
If you previously submitted your Personal Information to EON, and now wish to access it, update it or have it deleted from EON’s systems, please contact us at firstname.lastname@example.org.
15. Updates and Interpretation
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
You may also contact us by mail at:
11 W 30th Street, Floor 6, New York City, NY 10001