1. IMPORTANT INFORMATION
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Omnico Group collects and processes your personal data in the course of our business including through your use of our website, registration for an event and requests for information from us. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions.
This privacy notice is issued on behalf of Omnico Group. Omnico Group is made up of different legal entities, therefore references to “Omnico”, “we”, “us” or “our” in this privacy notice are referring to the relevant company in the Omnico Group responsible for processing your data (as applicable). For the avoidance of doubt, Omnico Group UK Limited is the data controller responsible for data collected through our website.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at email@example.com or Omnico Group, Head Office, Suite 29, 80 Churchill Square, Kings Hill, West Malling, Kent ME19 4YU.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (the UK supervisory authority for data protection issues www.ico.org.uk) or other supervisory authorities outside of the UK. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current, therefore please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links 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.
2. THE DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you such as:
- Identity Data includes first name, last name and title.
- Contact Data includes the name of the organisation you work for, address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, 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 our website.
- Profile Data includes information provided by you in surveys or form responses, including requests for information.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. We collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
3. 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 Data, Contact Data, Profile Data, Marketing and Communications Data by filling in forms, entering a promotion, completing a survey or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you communicate with us regarding our products and services.
- Third parties or publicly available sources. We may receive personal data about you from various third parties such as:
- Technical Data and Usage Data from analytics providers such as Google based inside or outside the EU.
- Identity and Contact Data from data brokers or aggregators based inside or outside the EU.
- Identity and Contact Data from publicly availably sources such as your organisation’s website or official registers (such as Companies House in the UK).
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data as the law allows us to, most commonly in the following circumstances:
- Where we need to perform the contract we have entered (or are about to enter) with you or the organisation you work for.
- 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.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of the ways we plan to use your personal data, which of the legal bases we rely on to do so and identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Basis for processing|
|To register you or the organisation you work for as a new customer||Identity, Contact||• Performance of Contract|
|To provide our products and services to you or the organisation you work for||Identity, Contact||• Performance of Contract|
• Necessary to comply with a legal obligation
• Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||Identity, Contact, Profile, Usage, Marketing and Communications||• Performance of Contract|
• Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity, Contact, Technical||• 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)|
• Necessary to comply with a legal obligation
|To deliver relevant website and other content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Identity, Contact, Profile, Usage, Marketing and Communication, Technical||• Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical, Usage||• Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Identity, Contact, Technical, Usage, Profile||• Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view and decide on what products, services and offers we think you may want or need, or what may be of interest to you or the organisation you work for (marketing).
You will receive our marketing communications if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving such marketing.
We will obtain your express opt-in consent before we share your personal data with any third-party company outside the Omnico Group for marketing purposes.
You can ask us to stop sending you marketing communications at any time by contacting us at email@example.com.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product or service purchase or other transactions with you or the organisation you work for where you are the designated contact.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason compatible with the original purpose. If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in paragraph 4 above:
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- 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 our privacy notice.
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.
6. INTERNATIONAL TRANSFERS
In the course of running our business, we may share your personal data within the Omnico Group and with our service providers. This may involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we 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 by the European Commission.
- 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 Europe.
Please contact us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 instruction, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. 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.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (data subject access request).
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons.
- 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.
- Request restriction of processing of your personal data.
- Request the transfer of your personal data to you or to a third party. 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.
- 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.
If you wish to exercise any of the rights set out above, please contact us at email@example.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, or 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).
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 which case, we will notify you and keep you updated.
External Third Parties means:
- Service providers acting as processors based in the UK, USA or any other jurisdiction in which we operate who provide IT and system administration services or marketing services.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK, USA or any other jurisdiction in which we operate who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in in the UK, USA or any other jurisdiction in which we operate who require reporting of processing activities in certain circumstances.
Internal Third Parties means other companies in the Omnico Group acting as joint controllers or processors and who are based in the UK or USA and provide marketing, IT and system administration services and undertake leadership reporting.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or designated contact for the organisation you work for or to take steps at your request before entering into such a contract.
This version of our privacy notice was last updated on 28 April 2021.