PRIVACY AND COOKIE POLICY

The NowCM Group (the “NowCM Group” or the “Group”), acting either through NowCM Luxembourg S.A., formerly european primary placement facility (eppf) S.A. ("NowCM Lux"), NowCM France, formerly NowCP S.A. ("NowCM France"), or eppf Services S.A. (“eppf Services”), including its branch known as eppf Services S.A. - Sucursal Em Portugal, is committed to protecting the privacy of its users and clients.

This Privacy and Cookie Policy (“Privacy and Cookie Policy”) is designed to help you understand what information we gather, how we use it, what we do to protect it, to assist you in making informed decisions, how we look after your personal data, tell you about your privacy rights and how the law protects you when

• you visit our Sites as defined in the next paragraph (regardless of where you visit it from);
• you access any of our digital services through our Sites or otherwise (the “Platform”); and
• we provide to you with our digital services either through the Platform, under our Accession Agreement or under any other legal basis (“ Services”).

Unless otherwise indicated below, this Privacy and Cookie Policy applies to any website that references this Privacy and Cookie Policy, any Group website (at www.nowcm.eu, www.nowcm.cloud, https://dataroom.nowcm.eu, https://ibiza.nowcm.eu, https://metroon.nowcm.eu and https://copa.nowcm.eu), any website or domain that redirects to our Group website, e.g. www.nowcm.co, as well as any data the Group may collect across partnered and unaffiliated sites (together with our website, the “Sites”). The terms “we ,” “us,” and “our” refer to the Group. “You” refers to you, as a person accessing our Sites or Platform or as a user of the Services, and to whom in each case this Privacy and Cookie Policy applies. “Customer” refers to any individual, business or organisation, including their employees, agents or contractors, who is using the Services, and to whom in each case this Privacy and Cookie Policy applies.

We reserve the right to change this Privacy and Cookie Policy from time to time by changing it on the Site and, if we have such information of you, by emailing you.

I. IMPORTANT INFORMATION

Purpose of this Privacy and Cookie Policy

This Privacy and Cookie Policy aims to give you information on how we collect and process your personal data through accessing our Sites, Platform or through your use of the Services, including any data you may provide through the Site.

The Site is not intended for children and we do not knowingly collect data relating to children.

Controller

In relation to the provision of our Services, the entity from which you are receiving specific services within NowCM Group will be the primary controller responsible for your personal data. 

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy and Cookie Policy. If you have any questions about this Privacy and Cookie Policy, including any requests to exercise your legal rights set out below. You can contact the data privacy manager by using the contact details set out below.

Contact Details

Lagoas Park, Ediûcio 5B, Piso 6,

Porto Salvo, Lisboa  

2740-245, Portugal

Telephone number: +352-2786-8000

You have the right to make a complaint at any time to the relevant national data protection authority based on the entity from which you received the service within our group.

For services provided by NowCM Lux or eppf Services, please address your complaint to the National Commission for Data Protection (Commission Nationale pour la Protection des Données – CNPD) of the Grand Duchy of Luxembourg (https://cnpd.public.lu).

For services provided by the branch of eppf Services in Portugal, please address your complaint to the Comissão Nacional de Proteção de Dados (CNPD) (https://www.cnpd.pt).

For services provided by NowCM France, please address your complaint to the Commission Nationale de l'Informatique et des Libertés (CNIL) (https://www.cnil.fr).

We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority, so please contact us in the first instance.

Changes to the Privacy and Cookie Policy

This version was last updated on 15th June 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our Sites may include links to third-party websites, plug-ins and applications. Clicking on those links, using 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 website, we encourage you to read the privacy notice of every website you visit.

II. CONSENT

By accessing our Sites or using our Services, you accept our Privacy and Cookie Policy and our Terms and Conditions, and you consent to our collection, storage, use and disclosure of your personal information as described in this Privacy and Cookie Policy. In addition, by using our Sites or our Services, or services across partnered and unaffiliated sites, you are accepting the policies and practices described in this Privacy and Cookie Policy. Each time you visit our Sites, or use the Services, and any time you voluntarily provide us with information, you agree that you are consenting to our collection, use and disclosure of the information that you provide, and you are consenting to receive emails or otherwise be contacted, as described in this Privacy and Cookie Policy. Whether or not you register or create any kind of account with us, this Privacy and Cookie Policy applies to all users of the Sites and Services.

III. INFORMATION WE COLLECT

We may collect both “Non-Personal Information” and “Personal Information” about you and our Customers. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. “Personal Information” includes information that can be used to personally identify you, such as your name, address and email address.

In addition, we may also track information provided to us by your browser or your mobile phone when you access the Sites, view or use the Services, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Sites or Services, the time and date of access, and other information that does not personally identify you. We use this information for, among other things, the operation of the Sites and Services, to maintain the quality of the Sites and Services, to provide general statistics regarding use of the Sites and Services and for other business purposes. We track this information using cookies, or small text files which include an anonymous unique identifier. Cookies are sent to a user’s browser from our servers or the servers from partnered and unaffiliated sites and are stored on the user’s computer hard drive or phone. Sending a cookie to a user’s browser enables us to collect Non-Personal Information about that user and keep a record of the user’s preferences when utilizing our Sites or Services, both on an individual and aggregate basis. The Group may use both persistent and session cookies; persistent cookies remain on your computer after you close your session and until you delete them, while session cookies expire when you close your browser. Persistent cookies can be removed by following your Internet browser help file directions. If you choose to disable cookies, some areas of the Sites or Services may not work properly.

We may collect, use, store and transfer also other kinds of personal data about you which we have grouped together follows:

• “Identity Data” includes first name, maiden name, last name, title and date of birth.
• “Contact Data” includes billing or corporate address, residential address, email address and telephone numbers.
• “Financial Data” includes financial service account numbers and financial reports or similar information about you or your business.
• “Transaction Data” includes details about payments to and from you, details on the issuance of registered or unregistered notes, and other details of the Services you have purchased from us.
• “Technical Data” includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Sites or Services.
• “Profile Data” includes your unique account reference number, transactions made by you on the Platform or via our Sites or Services, preferences, feedback, survey responses and other correspondence.
• “Usage Data” includes information about how you use our Sites and Services.
• “Marketing and Communications Data” includes your preferences in receiving marketing from us, and your communication preferences.

“Aggregated Data” may be derived from your personal data but is not considered Personal Information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature or the number of Service types that are purchased. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy and Cookie Policy.

We do not collect any “Special Categories of Personal Information” 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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we may have to cancel delivery of the Services you have with us but we will notify you if this is the case at the time.

IV. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, providing documentation or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

- purchase or use our Sites, Platform and Services;

- create an account on our Sites or otherwise;

- contact us to report a problem with the Sites or Services, or for other purposes;

- request marketing to be sent to you; or

- give us some feedback.

• Automated technologies or interactions. As you interact with our Sites or Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

- Technical Data from the following parties:

(a) analytics providers based outside the EU, including Google Analytics and StatCounter; and

(b) search information providers.

o Identity and Contact Data from know your customer services.

o Contact and Transaction Data from providers of technical, payment and delivery services.

o Identity and Contract Data from publicly available sources, such as the electoral role.

o Financial Data from private institutions who make such information available to us, such as credit reference agencies.

V. HOW WE USE AND SHARE INFORMATION

Personal Information

Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into 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.
• Where we need to comply with a legal or regulatory obligation.
• Where you have given us your consent of doing so.

In general, we do not sell, trade, rent or otherwise share your Personal Information with third parties without your consent. We may share your Personal Information with vendors and other third-party providers who are performing services for the Group, such as paying agents, custodians, auditors, corporate service providers, account banks, regulatory and tax authorities, IT providers, for example Zendesk.com. In general, the vendors and third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the Sites or Services they provide for the Group. For example, when you provide us with personal information to complete a transaction, place an order, arrange for a delivery, or return a purchase, you consent to our collecting and using such Personal Information for that specific purpose, including by transmitting such information to our vendors (and their service providers) performing these services for the Group.

However, certain third-party service providers, in particular any regulated services providers, have their own privacy policies in respect of the information that we are required to provide to them in order to use their services. For these third-party service providers, we recommend that you read their privacy policies so that you can understand the manner in which your Personal Information will be handled by such providers.

In addition, we may disclose your Personal Information if required to do so by law or if you violate our Terms and Conditions or any other binding agreement between us.

Non-Personal Information

In general, we use Non-Personal Information to help us improve the Sites and Services and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyse use patterns of the Sites and Services. This Privacy and Cookie Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our sole discretion.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of most of the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us (via ops@nowcm.eu or via the form below) if you need details about the specific legal ground we are relying on to process your Personal Information where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To provide you with our Sites	(a) Identity (b) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with our legal obligations
To register you as a new Customer or user	(a) Identity (b) Contact	Performance of a contract with you
To provide the Services to you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Necessary for the legitimate interests of others (preventing fraud)
To manage our relationship with you which will include: (a) Notify you about changes to our Terms and Conditions or Privacy and Cookie Policy (b) Ask you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated, study how Users and Customers use our Services and to improve our Services into the future)
To administer and protect our business and the Sites and Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Financial (d) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with our legal obligations
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how Customers and Users use our Services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Site, Services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of Customers and Users for our Services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about Services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our Services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you and send to you through our marketing messages. You will receive marketing messages from us if you have requested information from us, have participated in workshops, have expressed your interest in our products and Services or purchased Services from us and you have not opted out of receiving such marketing communication. We consider this necessary for our legitimate interest (to develop our Services and grow our business) and will provide any such marketing communication in a non-invasive basis.

Opting out

You can ask us to stop sending you marketing messages at any time. For details please see below under “YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL INFORMATION”.

Change of purpose

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (via ops@nowcm.eu or via the form below).

If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note, that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

VI. HOW WE PROTECT INFORMATION

We implement reasonable precautions and follow industry best practices in order to protect your Personal Information and ensure that such Personal Information is not accidentally lost, unlawfully accessed, disclosed, altered or destroyed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such precautions. By using our Sites and Services, you acknowledge that you understand and agree to assume these risks.

VII. DISCLOSURES OF YOUR PERSONAL DATA

We may have to or wish to share your Personal Information with the parties set out below (and in the Annex) for the purposes set out in the table in Clause V above.

• Our Group, including any subsidiaries, Branches, sister or parent companies as well as any service providers.
• Other Customers of the Services.
• Public databases and credit reference agencies who assist in providing the Services.
• Service providers who provide administrative, custodial, payment, marketing, IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Tax, regulatory and other authorities who require reporting of processing activities in certain circumstances, especially in the prevention of money laundering and fraud.
• 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 Information in the same way as set out in this Privacy and Cookie Policy.
• We may check the details you provide with fraud prevention agencies and share your information with them if we suspect fraud. It is important that you don’t provide false, inaccurate information or impersonate another individual.

We require all third parties to respect the security of Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers 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 instructions.

International Transfers

We may transfer your data outside of the European Economic Area (EEA) in order to provide you with the Sites, the Platform and the Services. Other Customers outside the EEA may view your Personal Information through our Platform. The disclosure of such data to other Customers is regulated in the relevant Accession Agreement with you and necessary for the performance of our contract with you so we can provide you with the Services and allow other Customers to interact on our Platform.

VIII. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In many cases this might not be subject to an end date.

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 unauthorised 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.

In some circumstances we may anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

VIIII. YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL INFORMATION

Under certain circumstances, you have rights under data protection laws in relation to your Personal Information.

• Access to information: You have the right to request a copy of the information the Group holds about you.
• Ensuring accuracy of information: the Group wants to make sure that your Personal Information is accurate and up-to-date. You may ask the Group to correct or complete information that is inaccurate or incomplete.
• Right to erasure: You may have a right to erasure, which is more commonly known as the “right to be forgotten”. This means that in certain circumstances you can require the Group to delete Personal Information held about you.
• Ability to restrict processing: You may also have the right to require the Group to restrict the Group’s use of your Personal Information in certain circumstances. This may apply, for example, where you have notified us that the information we hold about you is incorrect and you would like us to stop using such information until we have verified that it is accurate.
• Right to data portability: You may have the right to receive personal data we hold about you in a format that enables you to transfer such information to another data controller (e.g. such as another service provider).
• Review by an independent authority: You will always have the right to lodge a complaint with a supervisory body, including the CNDP as listed above.
• Preventing direct marketing/opting out: We do not sell your personal data. From time to time, we may send emails containing information about new features and other news about us. This is considered direct marketing. We will always inform you if we intend to use your personal data or if we intend to disclose your information to any third party for such purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out, we may continue to send you administrative emails and Service notices including, for example, periodic updates to our Service status. We will send you Service-related announcements on occasions when it is necessary to do so. For example, if our Sites or Services are temporarily suspended for maintenance, or a new enhancement is released, which will affect the way you use our Sites or Service, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. Where you opt out of receiving these marketing messages, this will not apply to Personal Information provided to us as a result of a Service purchase, warranty registration, Service experience or other transactions.
• Objecting to other uses of your information: You may also have the right to object to the Group’s use of your information in other circumstances. In particular, where you have consented to he Group’s use of your personal data, you have the right to withdraw such consent at any time.

If you would like further information on how you can exercise these rights, please email us via ops@nowcm.eu or via the form below.

No fee usually required

You will not have to pay a fee to access your Personal Information (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 Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information 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.

X. AGE OF CONSENT

By using the Service, you represent that you are at least 18 years of age.

XI. CHANGES TO OUR PRIVACY AND COOKIE POLICY

The Group reserves the right to change this Privacy and Cookie Policy and our Terms and Conditions at any time. If we decide to change this Privacy and Cookie Policy, we will post these changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. Any such modifications become effective upon your continued access to and/or use of the Sites and Services five (5) days after we first post the changes on the Sites or otherwise provide you with notice of such modifications. It is your sole responsibility to check this website from time to time to view any such changes to the terms of this Privacy and Cookie Policy. If you do not agree to any changes, if and when such changes may be made to this Privacy and Cookie Policy, you must cease access the Sites. If you have provided your email address to us, you give us permission to email you for the purpose of notification as described in this Privacy and Cookie Policy.

XII. LINKS TO OTHER WEBSITES

As part of the Sites or Services, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy and Cookie Policy applies solely to information collected by us through the Sites or Services. Therefore, this Privacy and Cookie Policy does not apply to your use of a third-party website accessed by selecting a link via our Sites or Services. To the extent that you access or use the Sites or Services through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

XIII. MERGER OR ACQUISITION

In the event we (or any third party service provider) undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy and Cookie Policy, and that any acquirer of our (or any third party service providers) assets may continue to process your Personal Information as set forth in this Privacy and Cookie Policy. If our information practices change at any time in the future, we will post the policy changes here so that you may opt out of the new information practices. We suggest that you check this Privacy and Cookie Policy periodically if you are concerned about how your information is used.

XIV. CONTACTING US & WITHDRAWING CONSENT

If you have any questions regarding this Privacy and Cookie Policy or the practices of this or any other Site, the Platform or the Services, or wish to withdraw your consent for the continued collection, use or disclosure of your Personal Information, please contact us via ops@nowcm.eu or via the form below.

XV. COOKIES

Cookies and how they benefit you

Our Sites use cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

Our cookies help us:

• Make our Sites, Platform and Services work as you'd expect
• Save you having to login every time you visit the Sites
• Remember your settings during and between visits
• Improve the speed/security of the Sites
• Allow you to share pages with social networks like Facebook or Twitter
• Continuously improve our Sites and Services for you
• Make our marketing more efficient

We do not use cookies to:

• Collect any personally identifiable information (without your express permission, except your IP address)
• Collect any sensitive information (without your express permission}
• Pay sales commissions

You can learn more about all the cookies we use below.

Granting us permission to use cookies

If the settings on your software that you are using to view this website (your browser} are adjusted to accept cookies we take this, and your continued use of our Sites to mean that you are fine with this. Should you wish to remove or not use cookies from our Sites you can learn how to do this below, however, doing so will likely mean that our Sites and Services will not work as you would expect.

More about our Cookies

Website Function Cookies

Our own cookies

We use cookies to make our Sites work including:

• Determining if you are logged in or not
• Remembering your search settlings
• Remembering if we have already asked you certain questions

There is no way to prevent these cookies being set other than to not use our site.

Third party functions

Our Sites, like most websites, include functionality provided by third parties. A common example is an embedded video.

Disabling these cookies will likely break the functions offered by these third parties

Social Website Cookies

So you can easily “Like“ or share our content on the likes of Facebook and Twitter we have included sharing buttons on our site. The privacy implications on this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks.

Anonymous Visitor Statistics Cookies

We use cookies to compile visitor statistics such as how many people have visited our Sites, what type of technology they are using (e. g. Mac or Windows which helps to identify when our Site aren't working as it should for particular technologies), how long they spend on the Sites, what page they look at etc. This helps us to continuously improve our Sites and Services. These so called “analytics” programs also tell us, on an anonymous basis, how people reached this site (e.g. from a search engine) and whether they have been here before helping us to put more money into developing our Services for you instead of marketing spend.

Turning Cookies Off

You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so however will likely limit the functionality of our and a large proportion of the world's websites as cookies are a standard part of most modern websites.

It may be that you concerns around cookies relate to so called "spyware". Rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive.

Cookie Settings

Some of the cookies used on our Sites

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

First Party

• OptanonConsent
• XSRF-TOKEN

Performance Cookies

These cookies collect information about how visitors use the website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

First Party

• _gat
• zte2095
• _gid
• _ga

Third Party

Statcounter:

• is_unique
• is_visitor_unique
• __cfduid

Functionality Cookies

These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

First Party

• __zlcmid

Third Party

static.zdassets.com:

• __zlcid

Other Cookies

First Party

• __zlcstore
• sc_is_visitor_unique
• eppf_sso_portal_session
• sc_is_visitor_unique

Third Party

widget-mediator.zopim.com:

• AWSALBCORS
• AWSALB

zdassets.com

• __cfduid

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Third Party

facebook.com

• datr (519 days)
• lu (519 days)

twitter.com

• auth_token (5504 days)
• twll (1852 days)
• secure_session (5504 days)
• guest_id (519 days)
• __utma (519 days)
• remember_checked (1852 days)
• remember_checked_on (1852 days)

google.com

• APISID (519 days)
• SSID (519 days)
• SID (519 days)
• SAPISID (519 days)
• HSID (519 days)

syndication.twitter.com

• lang (Session)

Last Updated: This Privacy and Cookie Policy was last updated on 15 June 2023.

ANNEX

This website uses Google Analytics. Google Analytics is a web analysis service of Google Inc. The information generated by the cookies on your use of the website (including your IP address) is transferred to servers of Google in the USA where it is saved. Google uses this information to evaluate your visit to the website, compile reports on the website activities for the website operator and offer further services associated with the use of the website and the internet. More information on Google’s privcay settings and terms is available here: https://policies.google.com/?hl=en-GB .

This website user Statcounter, a web analysis service of Statcounter Ltd. When a visitor requests pages from the NowCM site, Statcounter Web servers automatically log the browser's domain name, and IP address. This information is collected solely for statistical purposes and is not used to identify individuals. Personally identifiable information such as visitor's name, telephone number, postal address and email address are technically impossible for StatCounter to collect and no attempt is made to do so. The information that is recorded consists of the date and time of visit, ip address, browser (e.g. Firefox 3.5), operating system version (e.g. Windows XP), screen resolution (e.g. 800x600), referring link, the current page url and the current page title. To enable StatCounter.com to track whether a visitor has been to our website before (i.e. a first-time or returning visitor) StatCounter sends a cookie to your visitors' computer. This information is collected solely to improve the service we offer to you and statistical purposes and is not used to identify individuals. More information on StatCounter’s privcay settings and terms is available here: https://statcounter.com/about/legal/

Our Site is hosted by Amazon Web Services (“AWS”). AWS provides us with the online server infrastructure that allows us to provide the Sites to you. Your information, including Personal Information, may be stored through AWS’s servers. By using the Sites and Services, you consent to AWS’s collection, disclosure, storage, and use of your Personal Information in accordance with AWS’s privacy policy available at https://aws.amazon.com/privacy/.

Our Sites use other services and/or plug-ins that might have an impact on your privacy. These are, amongst others:

• Zendesk – for more information on privacy see https://www.zendesk.co.uk/company/customers-partners/privacy-policy/
• Zoho - for more information on privacy see https://www.zoho.com/privacy.html#long
• RingCentral - for more information on privacy see https://www.ringcentral.co.uk/legal/privacy-notice.html

Additional cookies might come from: DoubleClick, Quantcast.