CIE-Group Terms & Conditions: Critical Legal Risks and Compliance Gaps Exposed | Erayaha

Uncovering Legal and Financial Risks in CIE-Group’s Terms & Conditions

When we examined CIE-Group Ltd’s privacy and cookie policy, our analysis revealed several critical legal and logical issues that could expose the company to substantial regulatory fines, litigation costs, and reputational harm. For example, under the GDPR, fines can reach up to €20 million or 4% of annual global turnover for non-compliance. Below, we highlight four high-impact areas where CIE-Group’s current terms create significant risk—and how targeted improvements can protect both the business and its customers.

1. Ambiguous Consent for Marketing Communications CIE-Group’s policy states: "We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided." However, this clause does not specify the legal basis for processing nor does it require explicit consent for direct marketing, as mandated by GDPR and PECR. This exposes the company to regulatory scrutiny and potential fines for unsolicited communications.

Legal Analysis

high Risk

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Added

We may periodicallywill only send promotional emails about new products, special offers or other information which we thinkdirect marketing communications to you may find interesting using the email address whichif you have provided explicit, informed consent in accordance with applicable data protection laws, including GDPR and PECR. You may withdraw your consent at any time by following the unsubscribe instructions provided in each communication.

Legal Explanation

The original clause does not specify the legal basis for processing personal data for marketing purposes and fails to require explicit consent, as mandated by GDPR and PECR. The revised clause ensures compliance by requiring informed, opt-in consent and provides a clear mechanism for withdrawal.

2. Vague Data Retention and User Rights The policy lacks a clear statement on how long personal data is retained and omits details on users’ rights to erasure, restriction, or objection under GDPR. This omission can result in non-compliance penalties and erode user trust, especially as regulators increasingly audit data retention practices.

Legal Analysis

high Risk

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Added

We may collect the following information: name and job title contact information including email address demographic information suchretain personal data only for as postcodelong as necessary to fulfill the purposes outlined in this policy, preferences and interests other information relevantor as required by law. You have the right to order fulfilmentrequest access, customer service and direct marketing information contained in emailsrectification, erasure, restriction, or web forms submittedobjection to us your computer IP address and versionthe processing of web browser page tagging techniquesyour personal data, as well as the right to help us understand user experiencesdata portability, in accordance with GDPR.

Legal Explanation

The original clause fails to specify data retention periods and omits users’ statutory rights under GDPR. The revision clarifies retention practices and enumerates user rights, reducing compliance risk and enhancing transparency.

3. Incomplete Security Disclaimer and Limitation of Liability While the policy acknowledges that data transmission over the internet is not completely secure, it fails to clarify the company’s liability in the event of a data breach or unauthorized disclosure. Without a properly scoped limitation of liability, CIE-Group could face unlimited damages claims, especially if customer data is compromised.

Legal Analysis

medium Risk

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Transmitting data over the internet is generally not completely secure andWhile we cannot guarantee the security of your data in transmission. We are committedimplement appropriate technical and organizational measures to ensuring thatprotect your information is secure once it has been received by us. In order to prevent unauthorised access or disclosurepersonal data, we have put in place suitable physicalexpressly limit our liability for any unauthorized access, electronic and managerial proceduresloss, or disclosure of data to safeguard and secure the information we collect online; this information is held on secure serversmaximum extent permitted by law, except in cases of gross negligence or willful misconduct.

Legal Explanation

The original clause does not address the company’s liability in the event of a data breach. The revision provides a clear limitation of liability, which is essential to manage financial exposure and clarify legal obligations.

4. Insufficient Clarity on Third-Party Data Sharing The clause: "We will not sell, rent or give away information that personally identifies you to third parties except where elements of the business have been outsourced and the provision of such information is required for the delivery of our service to you," is overly broad. It does not specify safeguards, due diligence, or contractual requirements for third-party processors, as required by GDPR Article 28. This creates a compliance gap that could result in regulatory action and loss of customer confidence.

Legal Analysis

high Risk

Removed

Added

We will not sell, rent or give awayonly share personal information that personally identifies you towith third parties except where elements of the business-party service providers who have been outsourced and the provision of such information isentered into written agreements with us that include appropriate data protection obligations, as required for the delivery of our serviceby GDPR Article 28. We conduct due diligence to youensure that all third-party processors maintain adequate safeguards for your data.

Legal Explanation

The original clause is overly broad and does not specify contractual or due diligence requirements for third-party data sharing. The revision ensures that third-party processors are contractually bound to protect data, reducing regulatory and reputational risk.

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Conclusion: Proactive Legal Protection is Essential Our analysis shows that CIE-Group’s current terms expose the company to significant financial and reputational risks, including regulatory fines, litigation, and customer churn. By addressing these gaps with precise, compliant language, CIE-Group can strengthen its legal framework and build greater trust with users.

Are your company’s privacy policies robust enough to withstand regulatory scrutiny?
How much could a single compliance gap cost your business in fines or lost customers?
What steps can you take today to proactively manage legal risk?

**This analysis is for educational purposes only and does not constitute legal advice. For actual legal guidance, consult with a licensed attorney. This assessment is based on publicly available information and professional legal analysis. See erayaha.ai’s terms of service for liability limitations.**