Privacy Policy

Eranos Partners LLC is the data controller for the personal data described in this policy. Incorporated in the Republic of Georgia. Operating worldwide. You can reach us about anything in this policy at partners@eranospartners.com.

This policy covers eranospartners.com and the other websites we operate, together with the internal applications we use to run the business.

We measure website traffic using our own first-party analytics, which we built and host ourselves. We do not use Google Analytics and we do not run third-party advertising or tracking cookies for measurement.

Our analytics does not store anything on your device. There is no cookie, no local storage entry and no persistent identifier. For each page view we record the page address, the referring website, any campaign parameters in the link you followed, your country, and a coarse device type.

To count returning visits within a single day without identifying you, we create a one-way cryptographic hash of your IP address and browser user-agent string, combined with a secret value that changes every day. We do not store your IP address itself. The daily secret is deleted after three days, and once it is deleted the hashes can no longer be linked to each other or to anything else, by us or by anyone.

Our lawful basis is our legitimate interest in understanding how people find and use our sites. Because we store nothing on your device and hold no identifier that persists, this measurement does not require your consent.

If you complete a contact form or request access to our deal room, we collect the details you give us, such as your name, email address, organisation and the substance of your enquiry, together with any eligibility information you self-certify. We use this to respond to you, to assess eligibility, and to keep the records our own compliance obligations require.

Our lawful basis is the steps taken at your request before entering a contract, our legitimate interest in responding to enquiries, and our legal obligations where record keeping is required.

Where we run paid advertising, we may send a record of a completed action on our site, such as a purchase or a sign-up, back to the advertising platform that referred the visit. That record carries the platform’s own click identifier from the link you followed, the time and value of the action, and hashed technical identifiers. We do not send your name, email address or any other directly identifying information for this purpose.

We operate an internal application that connects to Google services on our own behalf, using accounts that belong to us. It is not a product offered to the public and it does not connect to any account except our own.

That application requests access to:

• Google Search Console, read only, to retrieve search performance and indexing information for the websites we own. This uses a service account that we add to our own Search Console properties as a restricted user.
• Google Ads, to read the performance of our own advertising campaigns, to manage those campaigns, and to upload records of conversions that took place on our own websites.

We use the data these services return solely to operate and improve our own marketing. We store it in our own database, hosted in the United Kingdom. We do not sell it, we do not use it for advertising to anyone other than through our own campaigns, we do not use it to train generalised artificial intelligence or machine learning models, and we do not allow humans to read it except where it is necessary to operate or debug the application, where we are required to do so by law, or where you have given us permission.

Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

We use a small number of service providers to run our systems. These currently include hosting and database providers, an email delivery provider, and the advertising and search platforms described above. Each acts on our instructions under a contract, and we do not sell personal data to anyone.

Some of these providers operate outside the United Kingdom and the European Economic Area. Where personal data is transferred, we rely on the appropriate safeguards permitted by law, including standard contractual clauses.

Daily analytics secrets are deleted after three days. Aggregated and hashed analytics records are kept for up to twenty-five months. Enquiry and access-request records are kept for as long as the relationship is live and then for the period our compliance obligations require, typically six years.

Under UK and EU data protection law you have the right to ask for a copy of the personal data we hold about you, to have it corrected or erased, to restrict or object to how we use it, and to receive it in a portable form. To exercise any of these, write to partners@eranospartners.com.

Please note that our website analytics is designed so that we cannot identify you from it. We will not be able to link an access or erasure request to a particular analytics record, and we are not required to collect additional information in order to do so.

If you are unhappy with how we have handled your personal data, you can complain to the UK Information Commissioner’s Office at ico.org.uk, or to the supervisory authority in your own country.

We update this policy when our systems or our obligations change. The date at the top records the current version.