This site is owned and operated by Incopro Limited, by and through Corsearch Inc., Corsearch, B.V. and their related entities (“we”, “us”, “our” “Incopro” or “Corsearch”). Your privacy is of the utmost of importance to us as a data controller and we are committed to protecting it through our compliance with this Privacy Policy. You should read and fully understand our Privacy Policy and the terms and conditions surrounding the capture and use of that information.

This Privacy Policy discloses what Personal Information we gather, how we use it, who we may share it with, and also contains further information, where applicable, about your rights in relation to your Personal Data under the General Data Protection Regulation (“GDPR”), California Consumer Privacy Act (“CCPA”), Personal Information Protection Law of the People’s Republic of China (“PIPL”) and other similar data protection laws. Please note that references in this Privacy Policy to the “GDPR” include the UK’s version of the GDPR, as implemented pursuant to the General Data Protection Act of 2018.

It is important that you read this Privacy Policy, together with any other privacy notice or fair processing information we may provide on specific occasions when we are collecting or processing Personal Information about you, so that you are fully aware of how and why we are using your information.

CHANGES TO THIS PRIVACY POLICY

We may occasionally update this Privacy Policy. When we do, we will revise the “last updated” date at the bottom of the Privacy Policy. Please ensure that you frequently check this Privacy Policy for any updates

COLLECTION OF INFORMATION

When we use the term “Personal Information,” we mean information that can be used to identify you as an individual person. We collect limited Personal Information you provide through this site or our services, including the following:

Category of Personal Information	Legal Bases for Processing
Contact Information including your name, address, email address, company/organization name and business phone number.	To provide services requested by you and to meet our contractual obligations (Art. 6 para. 1 (b) GDPR). Our legitimate interests (Art. 6 para. 1 (f) GDPR). Your consent (Art. 6 para. 1 (a) GDPR), where required and obtained.

Where we need to collect Personal Information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have entered (or are trying to enter) into with you. In such cases, we may be unable to provide the services you have requested.

HOW IS YOUR PERSONAL INFORMATION USED?

We will use the personal information you provide to us to:

• provide you with personalized visits to our site;
• provide you with our services which you have signed up for;
• share your personal information with other partners (detailed below);
• recommend goods, services or promotions which may be of interest to you (but only where you have consented to be contacted for such purposes);
• develop our offers and the layout of our site to ensure that our services are as useful and enjoyable as possible;
• contact you; and
• send out email alerts you may have signed up for.

We do not sell personal information subject to the CCPA (other than as part of the sale, transfer, or merger of all or parts of our business or our assets, as disclosed above) and have not done so in the last 12 months.

We do not transfer personal information subject to the PIPL to any foreign law enforcement and/or judicial bodies.

The legal basis for sharing of your Personal Information with other Incopro or Corsearch group companies is that this is necessary for our legitimate interests under Art. 6 para. 1 (f) GDPR. We have a legitimate interest in sharing your information for internal administrative purposes, in particular to offer and provide the Services and to deal with any inquiries in an efficient and high-quality manner. Where your Personal Information is transferred to other Incopro or Corsearch group companies, your Personal Information will be processed in accordance with this Privacy Policy.

In compliance with applicable data protection requirements, we require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our processors to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our authorization and instructions. Where applicable, our contracts with our data processors also include certain additional obligations required under the GDPR.

We may disclose depersonalized data (such as aggregated statistics) about the users of our site in order to describe our sales, customers, traffic patterns and other site information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes, but these statistics will include no personally-identifying information.

THE LEGAL DATA PROTECTION REQUIREMENTS

We regard the lawful and correct treatment of your personal information by us as very important to our successful operation, and to maintaining confidence between us and our users. We ensure that our organization treats personal information lawfully and correctly. To this end, we fully endorse and adhere to the ‘General Data Protection Regulation’, including the UK version of the GDPR, as implemented pursuant to the Data Protection Act 2018.

In particular, without your consent, or first amending this Privacy Policy to reflect any change in our usage of personal information:

• we will not use your personal information for any purpose that is incompatible with this Privacy Policy;
• we will only collect sufficient personal information for the uses set out above;
• we will endeavor to keep your personal information up-to-date;
• we will not retain your personal information longer than necessary unless required to do so by law;
• we will operate appropriate technical and organizational processes to protect your personal information against unauthorized or unlawful access or processing and against accidental loss or destruction. The detailed measures we take are described elsewhere in this Privacy Policy.

INTERNATIONAL TRANSFERS

Cookies are small files that websites save to your hard disk or to your browser’s memory.
We transfer your Personal Information within the Corsearch group of companies for business purposes only. This may involve transferring your data outside the European Economic Area (EEA), UK or China to other jurisdictions, which have not been deemed to offer adequate protection for your Personal Information by the European Commission or the UK Government or the Cyberspace Administration of China (as applicable).

In addition, some of our processors are based outside the EEA, UK or China, so their processing of your Personal Information will involve a transfer of data outside the EEA,  UK and China respectively.

Where applicable, to protect your Personal Information under the applicable laws, we ensure your Personal Information is adequately protected and that such transfers are carried out in accordance with the law by ensuring at least one of the following safeguards is implemented:

• the country to which a transfer is made has been deemed to provide an adequate level of protection by the European Commission, the UK Government, the Cyberspace Administration of China or other supervisory authorities (as applicable);
• there are specific contracts in place with the recipient of your Personal Information which have been approved by the European Commission, the UK Government, the Cyberspace Administration of China or other supervisory authorities (as applicable) as providing your Personal Information with an adequate level of protection; or
• in certain circumstances, where you have given us your explicit consent to the transfer of your Personal Information outside the EEA, UK and/or China.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information outside the EEA and UK or China.

RETENTION OF YOUR PERSONAL INFORMATION

We will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or tax requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

• Analysis cookies: they allow Incopro to quantify the number of users and thus carry out the statistical measurement of analysis that the users of the offered service make, which is then treated exclusively by us, except for those of third parties, which are used and managed by third companies and by us for statistical purposes. We analyze its navigation on our website with the aim of improving the content available.
• Behavioral advertising cookies: they will allow the management of the advertising spaces, that the publisher has included in a webpage, application or platform from which the service is provided. These cookies store information of the behavior of the users obtained through the continuous observation of their habits of navigation, which allows developing a specific profile to show advertising.

USE OF COOKIES

Cookies are small files that websites save to your hard disk or to your browser’s memory.
You have the ability to accept or decline cookies. Most Internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer. If you choose to decline cookies, you may not be able to fully experience the features of our site or other websites that you visit. A number of cookies used by Incopro last only for the duration of your web session and expire when you close your browser. Other cookies are used for a longer duration, where for example, Incopro is required to remember your login details for when you next return to the Website.

WHAT TYPE OF COOKIES DO WE USE?

• Analysis cookies: they allow Incopro to quantify the number of users and thus carry out the statistical measurement of analysis that the users of the offered service make, which is then treated exclusively by us, except for those of third parties, which are used and managed by third companies and by us for statistical purposes. We analyze its navigation on our website with the aim of improving the content available.
• Behavioral advertising cookies: they will allow the management of the advertising spaces, that the publisher has included in a webpage, application or platform from which the service is provided. These cookies store information of the behavior of the users obtained through the continuous observation of their habits of navigation, which allows developing a specific profile to show advertising.

We work with AddThis, a technology that allows websites and their users to share contents easily with others by means of exchange icons and social bookmarking sites. For more information about AddThis cookies, please click here.

To learn more about cookies and how to disable them we recommend you visit the Information Commissioner’s website here.
To learn more about cookies and how to delete them click here.

SECURITY

We take appropriate steps to protect your Personal Information against loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

Company employees who handle Personal Information are subject to policies and procedures to protect your Personal Information, are required to treat it confidentially and may not disclose it to unauthorized third parties. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, emails sent to or from this site or to Incopro may not be secure, and you should therefore take special care in deciding what information you send to us. Moreover, we have reasonable technical safeguards and security measures in place functionally with the site, but where you use passwords, ID numbers, or other special access features on this site, it is your responsibility to safeguard them.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION

If your Personal Information is protected under the GDPR or other similar data protection laws, under certain circumstances, you may have the right to:

Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to request a copy of the Personal Information we hold about you and to check that we are processing it lawfully.

• Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it.
• Object to the processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and, other than for the purposes of direct marketing, there is something about your particular situation which makes you want to object to processing on this ground. You have the right to object to our use of your Personal Information for direct marketing at any time.
• Withdraw your consent from our use your Personal Information for direct marketing purposes. This enables you to opt-out from any direct marketing communications, at any time. You have the right to opt (i) not to register to receive our electronic newsletters; and not to be contacted by telephone, direct mail or email.
• Request the restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of Personal Information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your Personal Information to another party. This right will only apply in limited circumstances, where we process your Personal Information based on your consent or where the processing of Personal Information is necessary for the performance of a contract between us.

Where applicable, to exercise any of these rights, please contact us.

The rights described herein are not absolute and we reserve all of our rights available to us under applicable law in this regard.

We do not discriminate against you, for example, by charging you a different price or offering a different level of service, for exercising any of these rights.

You also have the right to lodge a complaint with your competent Data Protection Supervisory Authority. We would, however, appreciate the opportunity to address your concerns before you approach a supervisory authority, so please contact us in the first instance.

CHILDREN’S INFORMATION

We do not knowingly collect information from children and Incopro does not target or direct our site to children

LINKS TO OTHER WEBSITES

Our site may contain links to other websites. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites.

CONTACT US

If you have any questions, comments, requests or concerns about this Privacy Policy or other privacy-related matters, or if you would like to exercise any of your rights in relation to your Personal Information, you may contact us in the following ways:

• Through our dedicated email address: privacy@corsearch.com
• By our toll-free phone number: 1-800-732-7241
• By completing the Privacy Webform on our website, to exercise your rights.
• By contacting our Chief Legal and Privacy Officer, Diane Fiddle, directly at: Diane.Fiddle@corsearch.com 
• By contacting our U.S. or European office by mail, Attention: Privacy Officer:
  1. Corsearch, Inc. 6060 North Central Pwy., Suite 334, Dallas, TX 75206;
  2. Incopro Limited, Old Change House, 128 Queen Victoria Street, London, England EC48 4BJ

Incopro Limited is registered with the Information Commissioner’s Office (registration number ZA83559). Corsearch, Inc. is registered with the Information Commissioner’s Office (registration number ZA419068).

Last updated August 2022.