V2, 27 Jul 2020
1 Introduction and general terms
Oxford Lab Technologies promises to take great care with your personal data, and we commit to protecting any personal information we obtain about you, whether you are visiting our website or use our products or services.
2 Who we are
Oxford Lab Technologies Ltd (“OLT” or “Company”) is a company registered in England (company number 10250680). Oxford Lab Technologies Ltd registered address is Kemp House, 160 City Road, London EC1V 2NX, UK.
3 Why we hold personal data
We hold and process customers’ personal data for a number of reasons:
- To keep a record of contact made and actions taken by our customers and our communications with them
- To send marketing information about our projects, products, or services where we have their consent or are otherwise allowed to
- To fulfil contractual obligations entered into with customers e.g. product purchases
- To record and analyse product or service performance
- To provide support and troubleshooting
- To ensure we do not send unwanted information to customers or members of the public who have informed us they do not wish to be contacted
4 When and why we will send you personalised marketing communications
OLT will only contact you for marketing purposes – for example keep you up to date on our work, or let you know of ways in which you can support that work – where we have your consent or we are otherwise allowed to do so (see section 5 for details).
We will make it easy for you to tell us if you would like to receive marketing communications from us and hear more about our work and the ways in which you would like to receive this information (post, email, SMS and phone). We will not send you marketing material if you tell us that you do not wish to receive it. There are a variety of ways you can do this, please see section 11 for details.
Where you give us your consent to send marketing information, we will wherever possible let you know how long this consent will last. Unless we have grounds for believing that a longer period is reasonable and have explained this to you, we will understand your consent to last for 24 months. After this time, in order for us to continue to update you, we will need your refreshed consent. You can update or withdraw your consent at any time, for individual channels of communication, or for all channels. See section 11 for details on how to do this.
5 How and when we collect information about you:
OLT may collect your personal data in the following circumstances:
When you give it to us DIRECTLY
You may give us your personal data directly when you communicate with us, or fill out a form on our website.
When you give it to us INDIRECTLY
You may give us your information indirectly when you use our products. For example your IP address or how you use our products may be recorded by our software.
Sometimes your personal data is collected by an organisation working on our behalf (for example a professional marketing agency) but as they are acting on our behalf we are the “data controller” and responsible for the security and proper processing of that data.
6 When you access OLT’s Social Media
We might also obtain your personal data through your use of social media such as Facebook, WhatsApp, Twitter or LinkedIn, depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.
7 When the information is publicly available
We might also obtain personal data about individuals who may be interested in our products or services or organisations like OLT. In this scenario, OLT may seek to find out more about these individuals, their interests and motivations for products and services through publicly available information. This information may include newspaper or other media coverage, open postings on social media sites such as LinkedIn, and data from Companies House. OLT will not retain publicly available data relating to major donors without their consent, which will be sought at the earliest practical opportunity.
If you visit our website as an anonymous visitor (e.g. you switch off cookies), OLT may still collect certain information from your browser, such as the IP address (an IP address is a number that can uniquely identify a computer or other internet device).
9 What information might OLT collect about you?
We only collect personal data relevant to the type of transactions you have with OLT.
For example, when you contact OLT to inquire about the product, purchase a product, or request support, or online content, such as newsletters, competitions, or message boards, or you telephone, email, write to or text OLT, or engage with OLT via social media channels, we may receive and retain personal information about you.
The information we collect is relevant to the type of transaction you are entering into with details such as your name, email address, postal address, telephone or mobile number, bank account details to process payments and your tax status for the purpose of collecting and charging tax such as VAT appropriately.
10 Sensitive Personal Data
We do not collect “sensitive personal data” about our customers, e.g. health status, unless there is a clear reason for doing so – such as participation in an event where we need this to ensure that we provide appropriate facilities or support to enable you to participate in the event. Clear notices will be provided on application forms for such events so that it is clear what information we need and why we need it.
All sensitive personal data is stored on a secure database, to which only a limited number of relevant staff have access. It is deleted when no longer relevant, is never shared with third parties, and is available to you at any point should you wish to see it.
11 How will OLT use your personal data?
OLT will use your personal information for the following purposes:
For administrative reasons, including:
- “service administration”, which means that OLT may contact you for reasons related to administering any purchases you have made and the completion of commercial or other transactions you have entered into with OLT or the activity or online content you have signed up for;
- to confirm receipt of products and services (unless you have asked us not to do this), and to say thank you.
- in relation to correspondence you have entered into with us whether by letter, email, text, social media, message board or any other means, and to contact you about any content you provide;
- for internal record keeping so as to keep a record of your relationship with us;
- to fulfil sales contracts you have entered into with OLT under which we are required to provide notifications to you;
- to keep your data up to date – for instance we use the Royal Mail’s data on postal address changes to ensure that we can maintain contact with you where we believe you are happy to be contacted by post;
- to implement any instructions you give us to with regard to withdrawing consent to send marketing;
- to use IP addresses to identify the location of users, to block disruptive use and to establish the number of visits from different countries.
- to use IP and any data available to our software products to analyse and improve activities relating to our software performance, user experience, usage, errors and provide support to our customers. We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
- For marketing reasons (see section 4 for details).
- For market research
- For product and service performance analysis and research
- to invite you to participate in surveys or research about OLT or our work (participation is always voluntary);
- to analyse and improve the activities and content offered by the OLT website to provide you with the most user-friendly navigation experience. We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
12 Will OLT share your personal information with anyone else?
We will only use your information within OLT for the purposes for which it was obtained. OLT will not, under any circumstances, share or sell your personal data with any third party for their own marketing purposes, and you will not receive marketing from any other companies or other organisations as a result of giving your details to us.
13 OLT’s suppliers
We may need to share your information with service providers who help us to deliver our projects, products and services, for instance through handling responses to our sales line. These “data processors” will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing strict data protection clauses. We do not allow these organisations to use your data for their own purposes or disclose it to other third parties without our consent and we will take all reasonable care to ensure that they keep your data secure.
14 Facebook and other Social Media Sites
We may also use your email address and phone number to match to your account on Facebook or other social media sites in order to show you OLT content while using these services. We only do this where you have opted in to marketing emails or phone calls and we keep your data secure by encrypting it. No data we hold about you is retained by the third party.
In addition, we may also use your email address and phone number to link to Facebook or other social media sites in order to identify other users of these sites whom we believe would be interested in OLT, and we may then show them OLT content. No data we hold about you is retained by the third party.
There are two ways to prevent this use of your data, you can either update your preferences at OLT by opting out of the relevant channel of communication or you can do this via the social media site:
Updating your preferences with OLT will not guarantee that you never see OLT content on social media, since the social media site may select you based on other criteria and without your data having been provided by OLT.
15 Where legally required
We will also comply with legal requests where disclosure is required or permitted by law (for example to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime, subject to such bodies providing us with a relevant request in writing).
Your data is only processed outside the EU where OLT has verified that appropriate standards and safeguards are in place.
16 How long will OLT keep your personal information?
We will hold your personal information on our systems for as long as is necessary for the relevant activity, for example we will keep a record of purchases for at least seven years to comply with HMRC rules.
If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
Where you contribute material to us, e.g. user generated content or in response to a particular campaign we will only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted unless otherwise stated at the point of generation.
17 How to control what we send you or request we update your personal information?
The accuracy of your information is really important to us. We want to ensure that we are able to communicate with you in ways that you are happy with, and to provide you with information that is of interest.
If you wish to change how we communicate with you, or update the information we hold, then please contact us:
- amend your preferences by contacting us on our website here: http://www.oxfordlabtech.com/contact
- email us at contact at oxfordlabtech.com
- write to us at: Oxford Lab Technologies Ltd, Kemp House, 160 City Road, London EC1V 2NX, UK
- Email – You can opt out of marketing emails at any time by clicking the unsubscribe link in any marketing email from OLT.
18 How long will it take for these changes to be effective?
We endeavour to meet the following service levels where supporters request we do not send them marketing information:
Email – 24 hours from receipt of email
Mail – 28 days from receipt of ‘do not mail’ request. This period is longer than for other channels due to the production times for mailing campaigns, and in most cases we would expect the change to be effective much more quickly.
Under the Data Protection Act you have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected (in line with standard guidelines for these requests we charge £10 for information requests and require you to prove your identity with two pieces of approved identification).
19 How OLT keeps your data safe
We ensure that there are appropriate technical controls in place to protect your personal details.
We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff and contractors.
We may use external companies to collect or process personal data on our behalf. We do comprehensive checks on these companies before we work with them, and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal data they collect on our behalf, or have access to. We have a robust partner monitoring framework to ensure these contractual obligations are met.
21 How to make complaints about this policy or raise privacy concerns
If you would like more information, or have any questions about this policy, please contact us by email at contact at oxfordlabtech.com or write to us at: Oxford Lab Technologies Ltd, Kemp House, 160 City Road, London EC1V 2NX, UK.
To make a formal complaint about OLT’s approach to data protection or raise privacy concerns directly with our data protection team, please contact:
The Data Protection Officer
Oxford Lab Technologies Ltd, Kemp House, 160 City Road, London EC1V 2NX, UK.
You also have the right to make a complaint direct to the UK’s data protection authority, the Information Commissioner’s Office (ICO). The ICO can be contacted at: https://ico.org.uk/global/contact-us/
Concerns can be also be logged via the ICO website.
23 Privacy FAQs
- Does OLT use profiling as part of its marketing campaigns?
- How we target our marketing campaigns (profiling)
Profiling is a common technique used in direct marketing and involves analysing data to improve the targeting of communications. OLT uses profiling techniques to help ensure our communications are relevant. Profiling allows us to target our resources effectively, which customers consistently tell us is a key priority for them. The data may have been provided to OLT by our customers or general public when responding to our marketing campaigns, or when using our website, products, or social media sites such as Facebook. It may also have been provided by external organisations as described below.
When building a profile we may analyse geographic, demographic and other information relating to you, as well as your previous responses to our marketing campaigns. We do this in order to determine whether we believe a particular marketing campaign might be of interest. Some of the data is provided by external organisations and may be provided at an aggregate level (e.g. by postcode). Where it relates to you as an individual we check that you have provided your express consent to the relevant third party for this use of your data. This helps to maximise the effectiveness of our campaigns and to minimise the wastage that would result from sending marketing information where it is not of interest.