Privacy Policy
1. Privacy Statement
Edgescan.com (the “Site”) is owned and operated by BCC Risk Advisory Limited (company registration number: 497804), trading as Edgescan, with registered office at Unit 701, Northwest Business Park, Ballycoolin Road, Dublin 15, Dublin, Ireland (“BCC Risk Advisory”).
BCC Risk Advisory is the controller and collects personal data on the Site. BCC Risk Advisory is committed to protecting your privacy. We have created this Privacy Statement to explain how we collect and use personal data.
If you have any questions or concerns about BCC Risk Advisory’s personal data collection and use practices, please send an email stating your questions or concerns, with the subject heading “Privacy Statement Question”, to marketing@edgescan.com.
The website is not intended for children and we do not knowingly collect data relating to children.
2. What Personal Data are Collected?
Personal data means any information about an individual from which that person can be identified.
We collect personally identifiable information about you if you choose to purchase, register or apply online for one of our products, services, promotions or other online activities. Our online activities include web seminars, support responses, user surveys, product demonstrations, registration for our partner program and access to downloadable software and documents.
When you register or apply for one of our online activities, you complete a form that may require you to provide personally identifiable information, including your full name, email address and telephone number.
The categories of personal data about you that we may collect, use, store and transfer are as follows:
Profile Data: includes your username, password, job title, service purchases or orders and/or services deliveries made by you, preferences, language settings, feedback and survey responses.
Transaction Data: includes details about payments to and from you and other details of services you have purchased from us and/or through our Site.
Contact Data: includes email address and/or your work email address, postal address and phone number.
Technical Data: includes information about your hardware, for example the model of the computer you use, your computer’s operating system version, browser plug-in types and versions and internet protocol (IP) address.
Content Data: includes any content that is posted, transmitted or otherwise made available and/or provided by you through the Site, including, without limitation, any text, reviews and/or attachments.
Usage Data: includes details of your use of our Site including but not limited to login information, how you interact with our Site, the resources that you access on the Site, whether this is required by us to improve the Site and/or user experience, fix usability issues, dimension our infrastructure or otherwise.
Communications Data: includes your communication/correspondence with us (via emails or otherwise), records of your discussions with our customer support teams, including call recordings, when you share comments and opinions with us, ask us questions or make a complaint, including when you phone us, your preferences in receiving marketing from us and our third parties and your communication preferences.
We use anonymous information, such as aggregate data about visitors to the Site, to determine how to improve the Site, marketing and services, how visitors find out about the Site and which of our online services most interest visitors to the Site. We also may share anonymous information with third parties. This anonymous information cannot be used to identify you personally. 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 Statement.
If you fail to provide personal data: Where we need to collect your personal data 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 or are trying to enter into with you (for example, insufficient registration information).
3. How does BCC Risk Advisory collect my personal data?
We will collect personal data about you as follows:
Information you give us. This is information (including Profile, Contact, Content, Usage and Communications Data) you consent to giving us about you by filling in forms on the Site (including surveys), using the Site or by corresponding with us (for example, by email). It includes:
- information you provide by purchasing, registering or applying online for one of our products, services, promotions or other online activities. Our online activities include web seminars, support responses, user surveys, product demonstrations, registration for our partner program and access to downloadable software and documents;
- information you provide when you register to use the Site by creating a user account;
- information you provide when you use the Site (by, for instance, requesting services from us or transacting on our Site);
- information you provide when you report a problem with the Site or our services; and
- when you contact us, any correspondence between you and us.
Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy (which is available on our website – https://www.edgescan.com/cookie-policy/) for further details.
Information we receive from other sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from providers of technical, cloud analytics and payment services including but not limited to: Google, Apple, Freshdesk, Mailchimp, Twilio, Amazon Web Services, Microsoft, Hubspot, Facebook, Twitter, LinkedIn.
- Publicly available sources such as Companies Registration Office inside Ireland.
4. Legal Basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
5. How does BCC Risk Advisory use my personal data?
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before your personal data is used;
- Where we need to perform a contract we are about to enter or have entered with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
- Where we need to comply with a legal or regulatory obligation.
- We use your personal data to deliver the services you have requested, to evaluate your registration or application for our products and services, to process your request for information and to contact you if we need more information.
We may use your personal data to contact you in connection with an inappropriate use by you of the Site.
We may also use your Contact Data:
- for internal marketing purposes to obtain feedback on our products, the Site or on other aspects of our business;
- to notify you of new products or services that we think may be of interest to you; and/or
- to send you promotional materials; and to provide you with a newsletter.
If you prefer not to receive promotional materials, our email newsletter or other forms of communication, you may opt-out by sending an email to the regional sales representative from whom you received the communication, asking us to drop you from our mailing or email lists.
6. Purposes for which BCC Risk Advisory will use my personal data
We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/activity | Type of personal data | Lawful basis for processing |
| To register you as a new user on our Site | Profile Contact | Your consent |
| To verify your identification | Profile Contact | Performance of a contract with you |
| To deliver our services to you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | Profile Contact Content Communications Device Financial Transaction | Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries | Profile Contact Content Communications | Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
| To notify you of changes to the Site or any of our services | Profile Contact | Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
| To ask you to complete a survey about our Site or services | Profile Contact | Necessary for our legitimate interests (to analyse how customers use our products/Site/services and develop our offerings) |
| To contact you directly in relation to any query you have raised about the Site and/or our services | Profile Contact | Performance of a contract with you |
| To administer and protect our business and the Site including content review, troubleshooting, data analysis and system testing | Profile Contact Content | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, cloud services) Necessary to comply with legal obligations (to remove inappropriate and/or unlawful contents) |
| To improve quality, stability and security of the Site and our services | Content Device Usage | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, cloud services; to ensure that the content of our Site is presented in the most effective manner for you) |
| To improve existing features of the Site and/or our services and develop new ones | Content Device Communications Usage | Necessary for our legitimate interests (for running and grow our business, provision of administration and IT services, network security, cloud services) |
| To deliver relevant Site contents and advertisements to you, and measure or understand the effectiveness of the advertising we serve to you | Profile Contact Usage Communications | Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our services, offers, marketing, customer relationships and experiences | Usage | Necessary for our legitimate interests (to define types of customers for our various offerings, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy) |
| To assist us with crime and fraud prevention such as identity checking | Profile | Necessary to comply with legal obligations (in connection with anti-money laundering) |
7. Cookies
For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy which is available on our website (https://www.edgescan.com/cookie-policy/)
8. Does BCC Risk Advisory share my personal data with anyone?
We may share your personal data with the third parties set out below and for the purposes set out in the above table:
- External third parties such as:
- Professional advisers including lawyers, bankers, auditors and insurers based in Ireland (or elsewhere) who provide consultancy, banking, legal, insurance and accounting services;
- The Irish Revenue, regulators and other authorities based in Ireland (or elsewhere) who require reporting of processing activities in certain circumstances; and
- Authorized resellers for the purpose of further marketing our products to you;
- Service providers such as Google, Apple, Freshdesk, Mailchimp, Twilio, Amazon Web Services, Microsoft, Hubspot, Facebook, Twitter, LinkedIn; and
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Statement.
Except as stated in this Privacy Statement, we will not sell, rent, share or otherwise disclose to third parties the personal data collected on the Site.
We may disclose your personal data when required by law or in the good-faith belief that disclosure is necessary to comply with the law.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
9. Does BCC Risk Advisory transfer personal data internationally?
Unless explicitly stated, we undertake to ensure that all your personal data resides within the European Economic Area (EEA).
Should we need to store or process your personal data outside of Ireland and the EEA, we will contact you to request your consent.
Should this occur, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EEA.
10. Data Security
The security and confidentiality of your personal data is extremely important to us. We have implemented technical, administrative, and physical security measures to protect your personal data from unauthorized access and improper use. From time to time, we review our security procedures in order to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
11. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see Your Privacy Rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) to improve our Site and services, in which case we may use this information indefinitely without further notice to you.
12. Your privacy rights
Except as otherwise stated in this Privacy Statement (including, but not limited to, sharing information with our third-party resellers), we do not share information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure. To prevent further disclosure of your personal information for use in direct marketing by a third party, do not opt-in to such use when you provide personal data on the Site. If you opt-in to receive communications from a third party, your information will be subject to the third party’s Privacy Statement. If you later decide that you do not want that third party to use your information, you will need to contact the third party directly, as we have no control over how third-parties use information. You should always review the Privacy Statement of any party that collects your information to determine how that entity will handle your information.
Under certain circumstances you have the following rights under data protection laws in relation to your personal data:
- Right to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- 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 request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Right to object to processing of your personal data 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- 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; or
- 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 request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at marketing@edgescan.com.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
13. How to Make a Complaint
In the event that you wish to make a complaint about how your personal data is being processed by us, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority who can be contacted as follows. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance:
| Contact | Data Protection Commission |
| Telephone | +353 57 8684800 / +353 761 104 800 |
| info@dataprotection.ie | |
| Post | Data Protection Commission 21 Fitzwilliam Square Dublin 2, D02 RD29 Ireland |
14. Changes to this Privacy Statement and your duty to inform us of changes
We may change this Privacy Statement at any time without notice. If we change this Privacy Statement, we will post the changed Privacy Statement on the Site so that you are always aware of what type of information we collect, how we use it and under what circumstances, if any, we disclose it to third parties.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data change during our relationship with you.
15. Third Party Links
Our Privacy Statement applies solely to data collection practices on the Site. The Site contains links to other sites. Please be aware that BCC Risk Advisory has no control or influence over the privacy practices of other web sites and that our Privacy Statement does not apply when you leave the Site. We encourage you to read the privacy policies of each web site you visit. We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these web sites.
Data Processing T&Cs
For the purposes of the General Data Protection Regulation (EU 2016/679), customers located in the European Union or the European Economic Area may enter into a Data Processing Agreement that includes the Standard Contractual Clauses adopted by the European Commission in order to further provide adequate safeguards with respect to the data processed under the BCC Risk Advisory Customer Terms of Service.