Privacy Policy

Your Data Controller and Data Protection Officer

EchoAgent Limited is your Data Controller and responsible for your Personal Data.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data, please contact the DPO using the details set out below:

• Email: support@echoagent.io
• Postal address: 167-169 Great Portland Street, London, W1W 5PF

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Processing Data on Behalf of a Controller and Processors' Responsibility to You

In discharging our responsibilities as a Data Controller, we have employees who will deal with your data on our behalf (known as “Processors”). The responsibilities below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see Legal Basis for Data Collection).
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data.
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor.
• Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights.
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller.
• Maintain a record of all categories of processing activities carried out on behalf of a Controller.
• Cooperate, on request, with the supervisory authority in the performance of its tasks.
• Designate a data protection officer where required by the GDPR, publish their details, and communicate them to the supervisory authority.
• Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations and to maintain their expert knowledge.
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller.
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

Legal Basis for Data Collection

Types of Data / Privacy Policy Scope

“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you, but this is the full scope of data that we collect and when we collect it from you:

• Profile/Identity Data: Data relating to your first name, last name, gender, and date of birth.
• Contact Data: Data relating to your phone number, addresses, email addresses, and phone numbers.
• Marketing and Communications Data: Your preferences in receiving marketing information and other communications from us.
• Billing Data: Information relating to your debit and credit card information, such as the name attached to your payment details and your billing address.
• Financial Data: Your banking details, e.g., account number and sort code.
• Transactional Data: Details and records of all payments you have made for our services or products.

We also collect, use and share Aggregated Data, such as data on interaction with our platform by end users. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents, and current and prospective business partners.

Special Categories of Personal Data: We do not collect any Special Categories of Personal Data about you (e.g., details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, or genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

• Consent: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or 'opt in' to a service.
• Contractual Obligations: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• Legal Compliance: We're required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• Legitimate Interest: We might need to collect certain information from you to be able to meet our legitimate interests—this covers aspects that can be reasonably expected as part of running our business, which will not have a material impact on your rights, freedom, or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

Your Rights and How You Are Protected by Us

Your Legal Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

• Right to be informed: You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.
• Right of access: This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request").
• Right to rectification: You have a right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Right to erasure: You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law.
• Right to object: You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right, and it only applies in certain circumstances:
  • Where we are processing your personal data for direct marketing purposes.
  • Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
• Right to restrict processing: You have the right to request the restriction or suppression of your personal data. Note that this is not an absolute right, and it only applies in certain circumstances:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Right to data portability: You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

If you wish to make a request under any of these rights, please contact us at support@echoagent.io.

Your Control Over Our Use of Your Personal Data

You may delete your account at any time – this will remove your account page from our systems and our related software.

We do not guarantee the ability to delete all stored data. If you would like us to delete or correct personally identifiable data, let us know and we will action your request as soon as practicable.

You can access information associated with your account by logging into your account you created with us.

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorised access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

How We Protect Customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality.

However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk.

If you believe that your interaction with us is no longer secure, please contact us.

Your Data and Third Parties

Sharing Your Data with Third Parties

We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors or affiliates, subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions.

We may also share Personal Data with interested parties in the event that we anticipate a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If EchoAgent Limited is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations, your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

Third-Party Links

This Site may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

How Long We Retain Your Data

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Age Limit for Our Users

You must not use EchoAgent Limited unless you are aged 16 or older. This website is not intended for children, and we do not knowingly collect data relating to children.