Privacy and Data Protection Policy
Oato LTD is registered in England and Wales under registration number 12166940 and our principal place of business is at 1 Pittman Way, Fulwood, Preston, PR2 9ZD.
VAT Number: 338031717
INTRODUCTION
Oato LTD (‘we’, ‘us’, or ‘our’) is committed to having the correct procedures in place to protect and respect your privacy, in line with the guidelines of the EU General Data Protection Regulation (“GDPR”).
We may need to gather and use certain information about individuals. This Privacy and Data Protection Policy explains in detail the data we collect, along with how it is handled, stored and how we keep it safe. These individuals can include customers, suppliers, business contacts, employees, users of our clients’ websites and other people that the organisation has a relationship with or may need to contact.
The policy applies to all Oato LTD employees and all Personal Data processed at any time by Oato LTD. The objective of the policy is to ensure that:
• We process Personal Data in compliance with the GDPR.
• Oato LTD and all its staff members are aware of all obligations and protocols when processing Personal Data.
• We protect the rights of the staff, customers and partners along with your own Personal Data.
• Oato LTD protects itself from the risks of a data breach.
TERMINOLOGY
• Data Controller: The organisation that determines the manner and purposes for which Personal Data is to be processed.
• Data Processor: The organisation or individual who processes Personal Data on behalf of the Data Controller.
• Data Subject: An individual who is the subject of Personal Data (also referred to as ‘you’, ‘your’, ‘yourselves’).
• Personal Data: Information relating to an individual who can be directly identified from the information. Personal Data includes factual information as well as expressions of opinion or intentions.
• Personal Data Breach: Loss, theft or unauthorised access, use or disclosure of Personal Data.
LEGAL BASIS FOR DATA COLLECTION
There are a number of various reasons that the law allows collection and process of personal data.
Consent: Certain situations allow us to collect your personal data, such as when you tick a box that confirms you are happy to receive email newsletters, or ‘opt in’ to a service.
Contractual Obligations: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
Legal Compliance: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
Legitimate Interest: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests.
PROCESSING DATA ON BEHALF OF A CONTROLLER
The GDPR defines a “processor” as “a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller”. Therefore, the responsibilities described below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Processor has the following responsibilities:
• Ensure that all processing of personal data is governed by a contract or other legal act that sets out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of the controller
• Process the personal data only on documented instructions from the controller, including with regard to transfers of personal data to a third party or an international organisation
• Ensure that persons authorised to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of personal data
• Obtain the prior specific or general written authorisation of the controller before engaging another processor
• Assist the controller in the fulfilment of the controller’s obligation to respond to requests for exercising the data subject’s rights
• Delete or return all the personal data to the controller after the end of the provision of services relating to processing
• Make available to the controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the controller or another auditor mandated by the controller
• Maintain a record of all categories of processing activities carried out on behalf of a controller
• Cooperate, on request, with the supervisory authority in the performance of its tasks
• Ensure that any person acting under the authority of the processor who has access to personal data does not process them except on instructions from the controller
• Notify the controller without undue delay after becoming aware of a personal data breach
• Designate a data protection officer where required by the GDPR, publish their details and communicate them to the supervisory authority
• Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to personal data and processing operations, and to maintain his or her expert knowledge
POLICY SCOPE
This policy applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of GDPR. This can include:
• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
NON-PERSONAL DATA
We may use anonymous data collected from the Oato website for site administration, analytics, advertising and promotional purposes, and we may share such information with other entities (such as service providers) for such purposes. We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on personal data, it does not identify you personally. Oato may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
We may use your anonymous data outside of Oato to improve third party marketing or use your data in combination with third party data to improve your experiences both in and outside Oato. We may retain your IP address and/or other device-identifying data in order to help us diagnose problems with our servers, to administer Oato including personalizing content or links relevant to your geographic area or device-type, to verify that your account is not being used by others, to gather broad anonymous demographic data (such as the number of visitors from a geographic area), to enforce compliance with our Terms of Use or otherwise in order to protect our services, Sites, customers, or other third parties.
We use analysis tools including Google Analytics, Mixpanel and/or others. These provide us with information about how our users use the Site.
WHAT CONTROL DO I HAVE OVER OATO’S USE OF MY PERSONAL DATA?
If you would like us to delete/correct personally identifiable data, let us know and we will action your request as soon as practicable. Please email hello@oato.co.uk
WILL WE SHARE YOUR DATA WITH THIRD PARTIES?
We will share your personal data with suppliers or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).
We may share non-personal data with third parties to, for example (but not by way of limitation), improve Oato and to enable data aggregation as described above.
We may also share personal data with interested parties in the event that Oato anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties.
If Oato is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your personal data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your personal data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).
We may share your personal data at any time if required for legal reasons or in order to enforce our Terms of Use or this Privacy Policy.
HOW DOES OATO PROTECT CUSTOMER DATA?
Oato is concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your personal data on our systems. Any personal data collected by us is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, we cannot ensure or warrant the security of any personal data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
COOKIES
Cookies are small files of letters and numbers downloaded onto your computer or access device when you access certain websites. The use of cookies is standard on the internet and many websites use them to improve the user experience. There are different types of cookies (described further below). For more information about cookies and how they work see allaboutcookies.org
BY USING THE OATO WEBSITE, YOU AGREE THAT WE CAN PLACE THE FOLLOWING TYPES OF COOKIES ON YOUR DEVICE:
1. Strictly necessary cookies – These cookies make our Site work. These cookies are essential in order to enable you to move around our Site and use our features, such as accessing secure areas. Without these cookies, we would not be able to remember your previous actions, determine whether you are logged in or not or enable you to see the electronic programme guide tailored to your chosen provider/region.
2. Performance cookies – These cookies improve the performance of our Site. These cookies collect information about how visitors use our Site, for instance which pages visitors go to most often, and if visitors get error messages from web pages. These cookies don’t identify you personally. All information these cookies collect is aggregated and anonymous. These cookies enable us to manage errors and the performance and design of the Site, to track ad response rates and your visits to our affiliate websites, and to show you which shows are most popular.
3. Functionality cookies – These cookies save you time. These cookies remember your user name and can also be used to remember settings that you can customise. These cookies allow us to remember choices you make (e.g. whether you want to share your activity on Facebook) and provide enhanced, more personal features. They may also be used to provide services you have asked for such as watching a video or commenting. Without these cookies, we won’t be able to distinguish you from other users and, as a result, save you time.
4. Targeting or advertising cookies – These cookies make the advertising you see relevant. These cookies are used to deliver adverts or links more relevant to you and your interests. They are also used to limit the number of times you see an ad as well as help measure the effectiveness of ad campaigns. They may be placed by us, or advertising networks with our, or our affiliate’s, permission. Without these cookies, you may still receive advertising – the advertising, however, will be less relevant to you.
5. Third party cookies – Our Site allows third parties to set cookies on your device (e.g. Facebook). This means that when we display content from a third party this third party may set their own cookies or similar technologies onto your device. We do not control the use of such cookies and in many instances have no access to the data collected by these third parties. Third party use of cookies is subject to their respective privacy policies.
HOW TO MANAGE COOKIES
You can manage cookies to a certain extent by amending and setting controls on your internet browser (e.g. via your “Preferences”). You should be able to:
(a) block specific cookies (e.g. from third parties and advertisers) or all cookies either across the web or from a particular website; and
(b) receive notifications when cookies are set.
You may also limit or prevent the placement of cookies by advertising networks or by setting your preferences for the major technology providers at choice.live.com
INDIVIDUALS UNDER 16 YEARS OF AGEYou must not use Oato unless you are aged 16 or older. If you are under 16 and you access Oato by lying about your age, or are otherwise in breach of our Terms and this Privacy Policy, you must immediately stop using the Oato website.
TRANSFER OF BUSINESS ASSETS
In some cases, we may choose to buy or sell business assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your personal information as set forth in this Privacy Policy.
NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated Sep 10, 2019. By using the Oato website, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of the Oato website shall constitute your express acceptance of any modifications to this Privacy Policy.
INTERPRETATION
All uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses put in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).
Our staff are not authorised to contract on behalf of Oato, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from an Oato address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Oato's rights, the email content shall be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Oato legal department.
HOW TO CONTACT US
If you have a question about this Privacy Policy or a complaint or want to know more about how your data may be used by us or would like to access or delete your data held by us or correct any inaccuracies, please email us at hello@oato.co.uk and we will respond as promptly as we can, or in the time period prescribed by law, whichever is sooner.
