We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we will explain how we collect, use and protect your personal data. We will also explain what rights you have with regards to your personal data and how you can exercise those rights.
1. Who we are
“We”, “Us” and “Our” refer to OmPrompt Limited, registered in England and Wales with company number 4452522. Our registered office address is 67 Innovation Drive, Milton Park, Abingdon, Oxfordshire OX14 4RQ. If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at firstname.lastname@example.org.
2. Collection of personal data
We collect personal data from you for one or more of the following purposes: 1. To provide you with information that you have requested or which we think may be relevant to a subject in which you have demonstrated an interest; 2. To ensure the security and safe operation of our websites and underlying business infrastructure, and 3. To manage any communication between you and us.
3. Registered users
In respect of Business Documents submitted to Us for processing, We act as a B2B processor. While we recognise that Business Documents we process may contain incidental personal data, for example an individual’s name and/or business email address may be included to assist communication, such personal data is not included within the fields that we digitise. We do not expect that you will require Us to process personal data, including special category data and criminal offence data, within the Business Documents submitted to Us for processing, other than temporarily storing a copy of the inbound Business Document, until it is purged from Our systems in accordance with agreed routines. To the extent, if any, that you do require Us routinely to process personal data, whether or not including special category data and criminal offence data, within the fields we digitise from the Business Documents submitted to Us for processing, We require you to have done everything necessary to ensure both that you are compliant with the GDPR in submitting that data to Us for processing, and that We may lawfully process that data on your behalf.
We do expect that in order to receive, process and return your data securely, to maintain an audit trail with full traceability, and to communicate with you, we will process personal data relating to your registered users, including name, job title, location, business email address and other contact details. We consider that user registration for these purposes is necessary in that it represents the most sensible, targeted and proportionate way of achieving those purposes. We have determined that the lawful basis for processing personal data relating to your registered users is that the processing is necessary for your legitimate interest in the security of your data and Our legitimate interest in providing you with a service in accordance with the commercial contract between you and Us, having considered whether there is a good reason to protect the personal data relating to your registered users which overrides those legitimate interests. Registered users will have the ability to access and verify their personal data and supplementary information, and may request a copy in a suitable form to meet the data portability requirement. Personal data will be rectified if it is inaccurate or incomplete, and will be erased where it is no longer necessary in relation to the purpose for which it was originally collected/processed.
The table in Section 5 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.
One type of cookie we use, a ‘persistent cookie’, is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual.
The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We also use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs.
Overall, these cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies, either by selecting accept or decline in the pop-up box on your first visit (in the latter case we will still set a cookie to record your preference for future visits), or by changing the settings in your web browser. Most web browsers are set by default to accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
We may also use a temporary form of cookie, known as a ‘session cookie’ as a portable authentication token that will enable registered users to move between different OmPrompt applications during a session. As this is considered ‘strictly necessary’, we do not seek a registered user’s consent before setting a session cookie.
Links to other websites – Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
However, we do not carry any third-party material on our website that would allow third party cookies to be set during your visit.
In Section 8 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.
5. Lawful basis for the processing of personal data
The table below describes the various forms of personal data we collect and the lawful basis for processing this data.
When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:
- The purpose test – is there a legitimate interest behind the processing?
- Necessity test – is the processing necessary for that purpose?
- Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights or freedoms?
|Purpose of Collection||Information Category||Data Collected||Purpose for Collection||Lawful basis for processing||Data shared with?||Retention period|
|1. To provide you with information||Subject matter information||Name, company name, geographic location, email address, business sector.||To provide appropriate online or email information about products and services that you have requested||Contractual fulfilment||Internally only||Maximum 8 years from the data the information is collected.|
|To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest.||Legitimate interest||Internally only||6 months if a marketing email is left unopened|
|Telephone number||Follow-up to ensure requested information meets needs and identify further requirements||Legitimate interest||Internally only|
|Personal contact information as provided through website forms or at trade shows or any other means||General mailing list subscription||Consent||Internally only|
|2. Security||Security information||Registered user details||To receive, process and return your data securely, to maintain an audit trail with full traceability, and to communicate with you.||Legitimate interest||Internally only||Relevant statutes of limitation|
|Your Internet Protocol (IP) address, login information, browser type and version, time zone setting, browser plug-in types and versions, Operating system and platform and clickstream.||To protect our websites and infrastructure from cyber attach or other threats and to report and deal with any illegal acts||Legitimate interest||Internally only||Relevant statutes of limitation|
|3. Communications||Contact information||Registered user details||To communicate with you about any issue that you raise with us or which follows from an interaction between us.||Legitimate interest||Internally only||Relevant statutes of limitation.|
6. Storage of personal data
OmPrompt Limited is a UK-domiciled organisation whose principal offices are in the UK.
- Our websites, platform and web applications are hosted in the EU and are accessed only by our UK-based staff.
- Our customer relationship management, marketing and accounting systems for all our businesses are either EU-based or hosted by companies participating in the EU – U.S. Privacy Shield Framework.
- Our banking arrangements are based in the EU.
- We operate a data retention policy in respect of all data, whether paper-based or digital and those aspects of it which relate to personal data are contained in the table (section 5) above.
7. Security measures
Our business management system (BMS) comprises an information security management system (ISMS) and a quality management system (QMS) and is certified to ISO/IEC 9001:2015 and ISO/IEC 27001:2013. We have what we believe are appropriate security controls in place to protect personal data. Risk assessment, including assessing risks to the rights and freedoms of data subjects, is at the heart of our ISMS. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.
8. Your rights as a data subject
As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email email@example.com or use the information supplied in the Contact us section below. In order to process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:
- The right to be informed
As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy notice and any related communications we may send you.
- The right of access
You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
- The purposes of the processing;
- The categories of personal data concerned;
- The recipients to whom the personal data has been disclosed;
- The retention period or envisioned retention period for that personal data; or
- When personal data has been collected from a third party, the source of the personal data.
- If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.
- The right to rectification
When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
- The right to erasure (the ‘right to be forgotten’)
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
- The right to restrict processing
You may ask us to stop processing your personal data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
- The accuracy of the personal data is contested;
- Processing of the personal data is unlawful;
- We no longer need the personal data for processing, but the personal data is required for part of a legal process; or
- The right to object has been exercised and processing is restricted pending a decision on the status of the processing.
- The right to data portability
You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.
- The right to object
You have the right to object to our processing of your data where:
- Processing is based on legitimate interest;
- Processing is for the purpose of direct marketing;
- Processing is for the purposes of scientific or historic research; or
- Processing involves automated decision-making and profiling.
Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner. Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union. For the United Kingdom, this is the Information Commissioner’s Office (ICO), who is also our lead supervisory authority. Contact information can be found at https://ico.org.uk/global/contact-us/.
10. Contact Us
Any comments, questions or suggestions about this privacy notice or our handling of your personal data should be emailed to firstname.lastname@example.org. Alternatively, you can contact us using the following postal address or telephone numbers:
67 Innovation Drive
Telephone: +44 (0)1235 436 000
Fax: +44 (0)1235 436 00