Contents

Unless otherwise expressly stated, terms in this Cookie Notice have the same meaning as defined in our Privacy Notice.

SCOPE OF NOTICE

This Cookie Notice supplements the information contained in our Privacy Notice by explaining how Encompass Digital, its affiliates and subsidiaries (collectively, “Encompass Digital,” “we,” “us,” “our”) and our business partners and service providers use cookies and related technologies in the course of managing and providing our online services and our communications to our users. It explains what cookies are and how we use them, as well as users’ rights to control our use of them.

WHAT ARE COOKIES AND RELATED TECHNOLOGIES

Cookies are small data files, which are downloaded to an individual’s browsing device (such as a computer or smartphone) when they visit a website. Cookies allow us and our third-party partners and providers to collect certain information about an individual’s interactions with our email communications, websites and other online services. We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).

WHAT WE COLLECT WHEN USING COOKIES

We and our third-party partners and providers may use cookies to automatically collect certain types of usage information when an individual visits or interacts with our email communications, websites and other online services. For example, we may collect log data about an individual’s device and its software, such as IP address, operating system, browser type, date/time of visit, and other similar information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure usage and activity trends for our online services.

HOW WE USE THAT INFORMATION

Cookies do lots of different jobs, like helping website operators understand how their website is being used, letting a user navigate between pages efficiently, remembering a user’s preferences, and generally improving browsing experience.  Cookies can also help ensure the advertisements an individual sees online are more relevant to their interests.

WHAT TYPES OF COOKIES ARE USED BY Encompass Digital?

The types of cookies used on Encompass Digital’s websites can generally be put into one of the following categories: strictly necessary; analytical or performance; functional; and targeting:

Strictly Necessary Cookies	These cookies are essential to making Encompass Digital’s websites work. They enable core functionality such as security, network management and accessibility. Without these cookies, services that are necessary for an individual to use a site, such as accessing secure areas or remembering the information inputted into a webform, are not available. These cookies do not track browsing history on non-Encompass-Digital.com websites. The legal basis for our use of strictly necessary cookies are our legitimate interests, namely being able to provide and maintain our website.
Analytical or Performance Cookies	These cookies collect information about how the number of visitors to our websites and online services, and to see how visitors move around our websites and online services when they are using them. This helps us to improve the way our websites and online services work, for example, by ensuring that users are finding what they are looking for easily. Information collected from these cookies may be aggregated and used on an anonymous basis. The legal basis for our use of analytical/performance cookies is an individual’s consent.
Functional Cookies	These cookies enable a website to remember information that changes the way the website behaves or looks, such as preferred language or the region that an individual is accessing our website from. The legal basis for our use of functional cookies is an individual’s consent.
Targeting Cookies	These cookies record an individual’s visit to our website, the pages they have visited and the links they have followed. They are used to track visitors across our websites. We use this information to make our website and the marketing messages we send to an individual more relevant to their interests. We may also share this information with third parties who provide a service to us for this purpose. The legal basis for our use of targeting cookies is an individual’s consent.Please see the Interest Based Advertising section below for more information.

The list of some of the specific cookies which are most frequently used by Encompass-Digital.com may be found in the Cookies Used By Encompass-Digital.com annex below.

HOW LONG WILL COOKIES STAY ON A BROWSING DEVICE

The length of time a cookie will stay on a browsing device depends on whether it is a “persistent” or “session” cookie.  Session cookies will only stay on a device until the individual stops browsing.  Persistent cookies stay on a browsing device until they expire or are deleted (i.e. after an individual has finished browsing).  Details of “persistent” and “session” cookies set on Encompass Digital websites can be found in the Cookies Used By Encompass-digital.com annex below.

FIRST- AND THIRD-PARTY COOKIES

“First-party cookies” are cookies that belong to Encompass Digital and that Encompass Digital places on a device.  “Third-party cookies” are cookies that another party places on a browsing device through an Encompass Digital website.

Third-party cookies set on an Encompass Digital website may provide a service or function to Encompass Digital, however, we are not always in control of how the third-party uses these cookies.  We recommend checking the third-party’s website for more information about how they use cookies.  Details of third-parties that set cookies through Encompass-Digital.com websites can be found in the Cookies Used By Encompass-digtial.com annex below.

CHOICES ABOUT COOKIES

If an individual prefers not to accept cookies, most browsers will allow them to: (i) change their browser settings to notify them when they receive a cookie, which lets them choose whether or not to accept it; (ii) disable existing cookies; or (iii) set their browser to automatically reject cookies. The following links may be helpful:

• • Cookie settings in Internet Explorer

• • Cookie settings in Firefox

• • Cookie settings in Chrome

• • Cookies settings in Safari web and iOS.

Cookies that are placed on an individual’s browsing device by a third-party can be managed through their browser (as described above) or by reviewing the third-party’s website for more information about cookie management and how to “opt-out” of receiving cookies from them. Some third-parties may use cookies to help gather information about an individual’s browsing activity so that they can deliver advertising to them on other websites relevant to their interests.

HOW WE USE TRACKING TECHNOLOGIES IN OUR EMAILS

Our emails may contain tracking pixels that identify if and when an individual has opened an email that we have sent them, how many times they have read it and whether they have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, provide more relevant emails to an individual’s interests and to know if an individual has opened and read any important administrative emails we have sent them.

An individual may set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our emails and performed certain functions with it.

Some browsers also give the option of downloading and installing extensions that block pixels and other tracking technologies.

INTEREST-BASED ADVERTISING

We have therefore developed this privacy policy to inform you of the data we collect, what we do with your information, what we do to keep it secure, as well as the rights and choices you have over your personal information.

We may share your personal data with other organisations in the following circumstances:

• • If the law or a public authority says we must share the personal data;

• • If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk);

• • From time to time, we will employ the services of other parties for dealing with certain processes necessary for the operation of the Website. However, all the information we share will be collected and anonymised, so neither you nor any of your devices can be identified from it; or

• • reCAPTCHA from Google helps protect websites from spam and abuse. A “CAPTCHA” is a test to tell human and bots apart. It is easy for humans to solve, but hard for “bots” and other malicious software to figure out. By adding reCAPTCHA to our site, we can block automated software while helping us welcome real users like you. First, the reCAPTCHA algorithm will check to see if there’s a Google cookie placed on the computer being used. Then, an additional reCAPTCHA-specific cookie will be added to your browser, and a complete snapshot of the browser window at that moment in time will be captured, pixel by pixel.

Some of the browser and user information collected at this time includes:

• • All cookies placed by Google over the last 6 months,

• • How many mouse clicks you’ve made on that screen (or touches if on a touch device),

• • The CSS information for that page,

• • The date,

• • The language your browser is set to,

• • Any plug-ins you have installed on the browser,

• • All JavaScript objects, and

• • The data you supply via the form

More information can be found at Google reCAPTCHA and Google’s Privacy Policy.

• • For the purpose of their promotional activities we will not share your information with any third parties for the purposes of direct marketing.

• • We use data processors who are third parties who provide elements of services for us. We have Data Processor Agreements in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us or further sub-processors who must comply with our Data Processor Agreement. They will hold your personal data securely and retain it for the period we instruct. The key processors we use are;

Type	Industry	Processor	Location
Accounting software	Finance	NetSuite	United States
Email/Cloud storage	IT	Microsoft	International
Client Management System	Operations	Hubspot	International

Encompass Digital is committed to transparency in the way we collect, process, share, and store your personal information within our environment. When we transfer any personal data to a data processor in a country without an adequacy decision by the EU Commission, we ensure that an adequate safeguard under GDPR Article 46 is present. We are aware of the recent Schrems II ruling and its implications on the U.S.-E.U. Privacy Shield and potentially the continued use of the Standard Contractual Clauses. When relying on Standard Contractual Clauses, evidence is available upon request from the data subjects.

We are diligently reviewing our privacy practices in light of this, but nevertheless remain devoted to handling your data in an ethical manner, including:

• • Processing your data only when it is fulfilling a contract or has a legitimate interest;

• • Mandating by contract that all sub-processors adhere to GDPR requirements;

• • Ensuring that any data transfers are encrypted in transit;

• • Storing your data on encrypted servers and networks;

• • Performing frequent penetration and firewall testing;

• • Undergoing yearly security audits;

We will continue to monitor guidance from authorities and stay closely aligned with these developments including adjusting our practices accordingly. 

We are committed to providing the information you request as part of your Subject Access Request and have procedures in place to ensure this occurs in a timely fashion.

We do have agreements in place with any third-party platforms that offer “Subject Access Requests as a Service”. As a responsible data controller of your personal information this represents significant risks when sharing data. The right of access afforded to you, does not obligate data controllers to share data with 3^rd parties. It is our policy to provide the information directly to data subjects ensuring the safety and security of the information throughout the process.

We will monitor future guidance from the Information Commissioner’s Office but currently undertake our own reasonable measures to verify the identity of data subjects. We would like to assure you that the protection of your data is our main concern and we are committed to providing information as part of any valid request.

CONTACT US

Please contact us by email at [email protected]  with any questions or comments regarding this Cookie Notice. Encompass Digital