PLEASE READ THIS POLICY CAREFULLY BEFORE USING THIS SITE
- WHO WE ARE AND CONTACT INFORMATION
- CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
- THIRD PARTY LINKS
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE THIS INFORMATION
- CHANGE OF PURPOSE
- DISCLOSURE OF YOUR INFORMATION
- INTERNATIONAL TRANSFERS
- DATA RETENTION
- YOUR RIGHTS
1. WHO WE ARE AND CONTACT INFORMATION
www.oxbowpartners.com (“our website”) is a site operated by Oxbow Partners Limited (“we”, “us” or “our”). We are the controller and responsible for your personal data. We are registered in England and Wales under company number 09863607 and have our registered office at 15 Bishopsgate, London, EC2N 3AR. We are on the Information Commissioner’s Office’s register of data controllers under number: ZA155900.
If you have any questions in relation to this policy, including any requests to exercise your legal rights, please contact us at: firstname.lastname@example.org or 15 Bishopsgate, London, EC2N 3AR.
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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2. CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This policy may vary from time to time so please check it regularly. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
3. THIRD PARTY LINKS
This 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. When you leave our website, we encourage you to read the privacy notice of every website you visit.
4. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, title, job title.
- Contact Data includes email address, postal address and telephone numbers.
- Usage Data includes information about how you use our website.
- Technical Data includes your internet protocol (IP) address together with the date, time and duration of your visit.
- Marketing and Communications Data includes your preferences in receiving marketing from us.
5. 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 and Contact Data by making a request to receive our newsletters by completing the form on our website, by corresponding with us by phone, e-mail or otherwise or by giving us your business card.
6. HOW WE USE THIS INFORMATION
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform a contract we have entered into with you.
- 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.
- Where you have provided your consent to us using your personal data for a specific purpose.
We have set out below a description of all the ways we may use your personal data. 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||Lawful basis for processing including basis of legitimate interest||Third parties to whom your personal data may be disclosed|
|To send you our newsletters||(a) Identity
(c) Marketing and Communications
(b) Necessary for our legitimate interests in conducting and managing our business (to develop our business)
|The Rocket Science Group LLC (d/b/a Mailchimp)
Dropbox International Unlimited Company
|To manage our relationship with you||(a) Identity
(c) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our client records updated)
|Dropbox International Unlimited Company
Projector PSA Inc.
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting)||(a) Identity
|(a) 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)
(b) Necessary to comply with a legal obligation
|Dropbox International Unlimited Company
Little Vitamin Ltd
|To make suggestions and recommendations to you about services or events that may be of interest to you||(a) Identity
|Necessary for our legitimate interests (to develop our services and grow our business)||Dropbox International Unlimited Company
The Rocket Science Group LLC (d/b/a Mailchimp)
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business)||Little Vitamin Ltd|
|To conduct market research||(a) Identity
|Necessary for our legitimate interests (to provide our services)||SurveyMonkey Inc.|
We may use your Identity and Contact Data to form a view on what we think may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing). You may receive marketing communications from us if you have requested information from us, purchased services from us or if you provided us with your business card and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
8. 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 and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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
9. DISCLOSURE OF YOUR INFORMATION
We may have to share your personal data with third parties set out in the table above and as set out below:
- Professional advisers including lawyers, accountants and insurers based in the United Kingdom.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
- 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 this 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.
In relation to any other third parties we will only disclose your information where you have given your consent or where we are required to do so by law, or where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights.
Some of the third parties listed above are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the 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.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. We have put in place appropriate security measures to prevent your personal data (once received by us) 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 instructions 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.
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.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- Request access to your personal data.
- 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 which will be notified to you, if applicable, at the time of your request.
- 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 wish to exercise any of the rights set out above, please contact us at email@example.com. You will not have to pay a fee. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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 this case, we will notify you and keep you updated.
Last updated: 22 May 2018