PRIVACY POLICY
PRIVACY POLICY

Privacy Policy

This Privacy Policy sets out how we, OKEUS LTD, collect, store and use information about you when you use or interact with our website, okeus.co.uk (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 29th November 2018.

Contents


  • Summary
  • Our details
  • When you visit our website
  • When you use our website
  • Marketing Communications
  • Information obtained from third parties
  • Disclosure and additional uses of your information
  • How long we retain your information
  • How we secure your information
  • Transfers of your information outside the European Economic Area
  • Your rights in relation to your information
  • Changes to our Privacy Policy
  • Children’s Privacy


Summary

This section summarizes how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

  • Data controller: OKEUS LTD
  • How we collect or obtain information about you: 
    • when you provide it to us e.g. by contacting us.
    • from your use of our website, using cookies and
    • occasionally, from third parties such as mailing list providers.
  • Information we collect: name, contact details, payment information e.g. your credit or debit card details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable), VAT number (if applicable), company type, engagement history and transaction history.)
  • How we use your information: for administrative and business purposes (particularly to contact you and process payments, to improve our business and website, to fulfil our contractual obligations, to analyse your use of our website, and in connection with our legal rights and obligations.)
  • Disclosure of your information to third parties: user information can be shared with partners for specific types of content and services where a client has registered their information. Other disclosures are only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you and where required by law or to enforce our legal rights.
  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No, OKEUS LTD does not sell data. However, depending on the requested service, your data can be shared with sponsors and partners. We will always make it clear where any information provided will be shared with other parties.
  • How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
  • How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology and only granting access to your information where necessary.
  • Use of cookies and similar technologies: we use cookies and similar information- gathering technologies such as marketing automation tracking on our website including essential, functional, analytical and targeting cookies. For more information, please visit our cookies policy here.
  • Transfers of your information outside the European Economic Area: In certain circumstances, we may transfer your information outside of the European Economic Area, including to the United States of America. Where we do so, we will ensure appropriate safeguards are in place, including, for example, that the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield. In the event of this, we will first seek consent from you to proceed.
  • Your rights in relation to your information 
    • to access your information and to receive information about its use o to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information o to complain to a supervisory authority
  • Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

Our Details

If you have any questions about this Privacy Policy, please contact the data controller. The data controller in respect of our website is;

OKEUS LTD

c/o sherrards Solicitors LLP 

1-3 Pemberton Row,

London, 

EC4A 3BG,

United Kingdom

You can contact the data controller by writing to our data protection officer using the address above or by sending an email to customer.services@okeus.co.uk

When you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

Web server log information

We use a third party server to host our website called SiteGround, the privacy policy of which is available here: https://www.siteground.co.uk/privacy.htm?scid=2&lang=en

We also use a Content Delivery Network (CDN) which improves the performance and security of our website.  We use Cloudflare to provide this service and their privacy policy can be found here: https://www.cloudflare.com/privacypolicy/

Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system

Use of website server log information for IT security purposes

We collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.

Use of website server log information to analyse website use and improve our website

We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser use.

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including essential, functional, analytical and targeting cookies. For further information on how we use cookies, please see our cookies policy which is available here.

You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using a cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

When you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Phone

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

When you use our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Newsletters

When you sign up for any of our newsletters from us by completing the newsletter sign up form, we collect your name, email address. We will also record the time and date of completion.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation). Consent: you give your consent to us sending you our newsletters by signing up to receive them using the steps described above.

We will also use this information to tailor any follow up sales and marketing communications with you. For further information, see the section of this privacy policy titled ‘Marketing Communications’.

Transfer and storage of your information

We use a third-party service to send out our e-newsletter and administer our mailing list, Mailchimp.

Information you submit to subscribe for our e-newsletter may be stored outside the European Economic Area on our third-party mailing list provider’s servers in the United States.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of tracking in emails

We use technologies such as tracking pixels (small graphic files) and tracked links in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates, click through rates and content engagement which our emails achieve.

Registering on our website

When you register and create an account on our websites, we collect the following information: your name, email address, address, location. We will also record the time and date of completion.

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: registering and administering accounts on our website to provide access to content, allows you to buy goods and services and facilitates the running and operation of our business.

We will also use this information to tailor any follow up sales and marketing communications with you. For further information, see the section of this privacy policy titled ‘Marketing Communications’.

Transfer and storage of your information

Information you submit to us via the registration form on our website may be stored outside the European Economic Area on our third-party hosting provider’s servers located in the United States of America.

When you place an order

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Information collected when you place an order

Mandatory information

When you place an order for goods or services on our website, we collect your name, email address, billing address.

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions

Additional information

We can also collect additional information from you, such as your phone number, full name, address etc.

We use this information to manage and improve your customer experience with us.

We will also use this information to tailor any follow up sales and marketing communications with you. For further information, see the section of this privacy policy titled ‘Marketing Communications’.

If you do not supply the additional information requested at checkout, you will not be able to complete your order as we will not have the correct level of information to adequately manage your account.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: The ability to provide adequate customer service and management of your customer account.

Processing your payment

After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use;

Payment Gateway 

(third-party payment processor)

Privacy Policy

Paypal

https://www.paypal.com/en/webapps/mpp/ua/privacy-full

Worldpay

https://www.worldpay.com/uk/worldpay-privacy-notice

Your payment will be processed by our payment processors, who collect, use and process your information, including payment information, in accordance with their privacy policies.

Transfer and storage of your information

In providing Paypal, Paypal transfers personal data outside the EEA.

In providing Worldpay, Worldpay retains personal data inside the EEA.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

Marketing communications

Our content, goods and services

When signing up for content, registering on our website or making a payment, we will use the information you provide in order to contact you regarding related content, products and services.

We will continue to send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.

You can opt-out from receiving marketing communications at any time by emailing customer.services@okeus.co.uk

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: Sharing relevant, timely and industry-specific information on related business services.

Transfer and storage of your information

We use a third-party service to send out our marketing emails and administer our mailing list, Mailchimp

Information for marketing campaigns will be stored outside the European Economic Area on our third-party mailing list provider’s servers in the United States.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of tracking in emails

We use technologies such as tracking pixels (small graphic files) and tracked links in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates, click through rates and content engagement that our emails achieve.

Third party goods and services

In addition to receiving information about our products and services, you can opt in to receiving marketing communications from us in relation third party goods and services by email by ticking a box indicating that you would like to receive such communications.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you information about third party goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

We use a third-party service to send out our marketing emails and administer our mailing list, Mailchimp.

Information for marketing campaigns will be stored outside the European Economic Area on our third-party mailing list provider’s servers in the United States.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of tracking in emails

We use technologies such as tracking pixels (small graphic files) and tracked links in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates, click through rates and content engagement that our emails achieve.

Information obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

We can often receive information about you from third parties. The third parties from which we receive information about you can include partners and other organisations that we have a professional affiliation with.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub- contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one.

In certain circumstances will also obtain information about you from private sources, both EU and non-EU, such as marketing data services.

We will continue to send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.

You can opt-out from receiving marketing communications at any time by emailing customer.services@okeus.co.uk

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

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