This document explains how we use your personal data.

We, Oohalo are committed to ensuring your privacy, our client’s privacy and the privacy of our subscribers and website visitors. In this policy we explain how we hold, process and retain your personal data.

1. How we use your personal data

1. This section provides you with information about:

1. what personal data we hold and process;
2. in respect of personal data that we did not collect from you directly, where we obtained that data from, and what types of data we have collected;
3. the purposes for which we may process your personal data; and
4. the legal grounds on which we process your data. 

2. Contact data. We may process information that you provide to us, or that is provided to us by your employer, if you are employed by one of our corporate clients which has a contractual arrangement with us for the provision of services (the “corporate client”). This may include information such as your name, email address, telephone number and employment details (the “contact data”). We may use this information to enable us to:

1. provide you with a quote for our services;
2. provide services to you, whether this is to you directly or in accordance with the contract that we have with the corporate client;
3. communicate with you regarding the provision of such services; and
4. improve the services that we provide and to ensure that we maintain our levels of client care.

Where you are employed by a corporate client, we will process any such personal data referred to in this paragraph 1.2 strictly in accordance with the instructions of the corporate client, not the individual point of contact, including sharing all such data with the corporate client. We will treat the corporate client as the controller of any contact data that we are provided with.

The legal basis for this processing is our legitimate interests in providing our products or services to you, or the corporate client, and in managing and administering our relationship and contract with you or the corporate client.

We may also use this information to contact you regarding the latest promotions and offers regarding our products and services, and send you newsletters. Where you are employed by a corporate client, the legal basis for this processing is our legitimate interests, namely the marketing of relevant products and services to the corporate client. 

Where you are an individual, sole trader, or working in a partnership and have provided your consent for us to do so, we may contact you regarding the latest promotions and offers regarding our products and services, and those of our partner organisations, and to send you newsletters.

3. Website data. We may process data about your use of our website and services ("website data"). The website data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the website data is our analytics tracking system. This website data may be processed for the purposes of analysing the use of the website and services. 

The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

4. Enquiry data. We may process information contained in any enquiry you submit to us regarding our products or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. 

The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

5. Subscription data. We may process information that you or the corporate client provide to us for the purpose of subscribing to our subscription service ("subscription data"). The subscription data may be processed for the purposes of sending you information about us, provide you with our latest promotions and offers regarding our products and service and our newsletters and allowing you to download our content. 

Where you are employed by a corporate client, the legal basis for this processing is our legitimate interests, namely the marketing of relevant products and services to the corporate client. 

Where you are an individual, sole trader, or working in a partnership and have provided your consent for us to do so, we may contact you regarding the latest promotions and offers regarding our products and services, and those of our partner organisations, and to send you newsletters.

If you opt-in to our mailing list, you will receive emails that may include company news, updates, related product or service information. If at any time you wish to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each e-mail.

6. Correspondence data. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. 

The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

7. Account Data. If you or the corporate client set up a client account with us for the purposes of receiving our products and services, you or the corporate client may provide us with information about yourself (“account data”). This account data may include your name, title, email address, company name, telephone number, your login information including login email/username and password, and any other information about you that is uploaded to the account. This may include a blend of technical information and personal data.

We may use this data to provide you with services from our web site, to monitor and administer your account with us. The legal basis for this processing is our legitimate interests in providing our products or services to you, or the corporate client.

8. Profile data – Job applications. We may process employment information that you provide to us ("profile data"). This profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details, employment history, curriculum vitae, job preferences and employment details. We will process your profile data in relation to job vacancies that you have applied for, generally processing any job applications, facilitating the recruitment process and furthering our relationship with you. The legal basis for this processing is our legitimate interests in finding an appropriate person for a particular role.  

We may consider you for opportunities that you did not specifically apply for but which we think might be a good fit for your skillset. The legal basis for this processing is our legitimate interests in finding an appropriate candidate for particular roles and vacancies. 

Where you have given us consent to process your information for the purposes detailed above, we will enter the profile data into our central recruitment database (“talent pool”). The legal basis for this is our legitimate interests in maintaining a viable talent pool.

9. Other processing activities. In addition to the specific purposes for which we may process your personal data set out above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2. Providing your personal data to others

1. To our partner service providers. We may share your data to our partners who manage and support us such as the various couriers that we use, and other service providers such as Intercom, Mixpanel, Full story, Hubspot, CSM and ITD, Gophr, Zendesk, Google Suites, Xero, AWS, Hubspot, Logz.io, Mailgun, Twillio, VoipFone, and Hellosign. We may also share your data with other companies within our group of companies. 

In the majority of cases we will only share your information with such third parties for the purposes of performing our contracts with, and providing our products and services to, our customers, and for the purposes of continually improving the products and services that we provide.

However, we may also receive your data from third-party service providers such as Barbour ABI before we have discussed our products and services with you, including your name, email address, telephone number and employment position. This personal data may be transferred to Hubspot where it will be stored.

2. Our insurers/professional advisers. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
3. Social Media Platforms. We operate the following social media pages Facebook, LinkedIn, Instagram, YouTube and Twitter. If you join one of our Social Media pages, please note that the provider of the social media platforms have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data on our social media pages.  
4. Where we provide your personal data to any third party. Where we share your personal data with any third party, we will ensure this processing is protected by appropriate safeguards including a suitable data processing agreement with that third party. 
5. To comply with legal obligations. In addition to the specific disclosures of personal data detailed above, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation we have to comply with, or in order to protect your vital interests or the vital interests of another individual.

3. Transfers of your personal data outside of the European Economic Area 

Where your personal data is transferred outside of the EEA, we will ensure that either (a) The European Commission has made an "adequacy decision" with respect to the data protection laws of the country to which it is transferred, or (b) we have entered into a suitable data processing agreement with the third party situated in that country to ensure the adequate protection of your data. In all cases, transfers outside of the EEA will be protected by appropriate safeguards.

4. Retaining and deleting personal data

1. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 
2. Unless we contact you and obtain your consent for us to retain your personal data for a longer period, we will retain and delete your personal data as follows:

1. Contact data will be retained for 2 years following the date of the last contact or correspondence we received from you, at the end of which period it will be deleted from our systems.
2. Website data will be retained for 2 years following the date of the last contact or correspondence we received from you, at the end of which period it will be deleted from our systems.
3. Enquiry data will be retained for 2 years following the date of the last contact or correspondence we received from you, at the end of which period it will be deleted from our systems.
4. Subscription data (other than subscription data that is also Contact data) will be retained for 2 years following the date of the last contact or correspondence we received from you, at the end of which period it will be deleted from our systems.
5. Correspondence data will be retained for 2 years following the date of the last contact or correspondence we received from you, at the end of which period it will be deleted from our systems.
6. Account personal data will be retained for 6 years following the date of the last contact or correspondence we received from you, at the end of which period it will be deleted from our systems. We have a contractual right to retain any technical data held in your account.
7. Profile data will be retained for 2 years following the date of the last contact or correspondence we received from you, at the end of which period it will be deleted from our systems.

3. We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5. Amendments

1. We may update this policy from time to time by posting a new version on our website.
2. You should check this page occasionally to ensure you review any changes to this policy.
3. We may notify you of changes to this policy by email.

5. Your rights

1. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to: 

1. your request not being found to be unfounded or excessive, in which case a charge may apply; and
2. the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

2. We may withhold personal information that you request to the extent permitted by law.
3. You may instruct us at any time not to process your personal information for marketing purposes.
4. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
5. The rights you have under data protection law are:

1. the right to access;
2. the right to rectification;
3. the right to erasure;
4. the right to restrict processing;
5. the right to object to processing;
6. the right to data portability;
7. the right to complain to a supervisory authority; and
8. the right to withdraw consent.

6. Your right to access your data. You have the right to ask us to confirm whether or not we process your personal data and, to have access to the personal data, and any additional information. That additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that personal data. You may request a copy of your personal data. The first copy will be provided free of charge, but we may charge a reasonable fee for additional copies.
7. Your right to rectification. If we hold any inaccurate personal data about you, you have the right to have these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to have any incomplete personal data about you completed.
8. Your right to erasure. In certain circumstances you have the right to have personal data that we hold about you erased. This will be done without undue delay. These circumstances include the following: it is no longer necessary for us to hold those personal data in relation to the purposes for which they were originally collected or otherwise processed; you withdraw your consent to any processing which requires consent; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure, including where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for establishing, exercising or defending legal claims.
9. Your right to restrict processing. In certain circumstances you have the right for the processing of your personal data to be restricted. This is the case where: you do not think that the personal data we hold about you is accurate; your data is being processed unlawfully, but you do not want your data to be erased; it is no longer necessary for us to hold your personal data for the purposes of our processing, but you still require that personal data in relation to a legal claim; and you have objected to processing, and are waiting for that objection to be verified. Where processing has been restricted for one of these reasons, we may continue to store your personal data. However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
10. Your right to object to processing. You can object to us processing your personal data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.
11. Your right to object to direct marketing. You can object to us processing your personal data for direct marketing purposes. If you make an objection, we will stop processing your personal data for this purpose.
12. Your right to object for statistical purposes. You can object to us processing your personal data for statistical purposes on grounds relating to your particular situation, unless the processing is necessary for performing a task carried out for reasons of public interest.
13. Automated data processing. To the extent that the legal basis we are relying on for processing your personal data is consent, and where the processing is automated, you are entitled to receive your personal data from us in a structured, commonly used and machine-readable format. However, you may not have this right if it would adversely affect the rights and freedoms of others.
14. Complaining to a supervisory authority. If you think that our processing of your personal data infringes data protection laws, you can lodge a complaint with a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
15. Right to withdraw consent. To the extent that the legal basis we are relying on for processing your personal data is consent, you are entitled to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
16. Point of Contact Data.  Paragraphs 6.1 – 6.15 shall not apply to any data about individuals employed by a corporate client, obtained or processed by us, in connection with a contract for the provision of products or services between us and the corporate client. In respect of such data:

1. Such individuals should contact the corporate client to exercise the rights set out in this paragraph 6.  

17. Exercising your rights. You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified above.

7. Cookie Policy

For information about how we use Cookies please see our Cookie Policy. 

8. Our details

1. You can contact us:

1. using our website contact form;
2. by telephone, on the contact number published on our website from time to time; or
3. by email, using the email address published on our website from time to time.

9. Data Protection Contact 

For further information about how we collect, process and secure your data contact us by email at: hello@oohalo.com  or by telephone on: 98489 10294.