Thank you for visiting Oxera’s website www.oxera.com.
This Privacy and Cookie Policy (‘Policy’) applies to the entire Oxera Consulting group, so references to Oxera, We, Us or Our are to the relevant company within the Oxera group responsible for processing your data (in the UK this is Oxera Consulting LLP, Oxera Consulting (France) LLP, Oxera Consulting (Netherlands) LLP and in Germany it is Oxera Consulting GmbH).
We are committed to safeguarding the privacy of Our website visitors, service users and other individuals with whom We deal. We are certified for Cyber Essentials, so you can be assured that your personal data is protected from cyber threats.
Key definitions
The GDPR applies to ‘controllers’ and ‘processors’.
A controller determines the purposes and means of processing personal data.
A processor is responsible for processing personal data on behalf of a controller.
This Policy sets out information about how We use, store and transfer personal data. We are a data controller in relation to that personal data, which means We determine the purposes and means of the processing of that personal data.
We have a responsibility to ensure that your personal data is protected, which We take very seriously, and We are committed to keeping your information safe and secure.
Key principles:
- Lawfulness, fairness and transparency
- Purpose limitation
- Data minimisation
- Accuracy
- Storage limitation
- Integrity and confidentiality (security)
- Accountability
Information we collect about you:
a) Usage data:
To ensure that Our website is useful to all visitors and continues to improve, We may process data about your use of the site. This may include your 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 use. This data, obtained through Google Analytics, is aggregated and anonymised such that it contains no information pertaining to any identifiable individual; as such, it is not personal data per se, but We believe in transparency and are addressing it here for completeness’s sake.
b) Correspondence data:
We may process information contained in or relating to any communication that you send to us, whether through the site, by email, through social media, or otherwise. This may include the communication content and metadata associated with the communication, as well as any contact details you provide to us, such as your name, email address, phone number, job title, address or social media username. We process correspondence data for the purposes of communicating with you and record-keeping.
c) Enquiry data:
We may process information contained in any enquiry you submit to Us indicating your interest in Our services or business, such as the contents of your enquiry and any contact details you provide to us, such as your name, email address, phone number, job title or address. We shall only process such data for the purposes of addressing your enquiry and, where you have opted-in, providing you with occasional news about Our services and operations. You can unsubscribe at any time.
d) Project data:
Where We are commissioned to undertake a particular piece of work or project, We will only process information for the purposes of setting up that project in Our systems, such as your name and contact details. We may also process personal information contained within project-related correspondence and documents, including in relation to your customers, whether created by Us or provided to Us. All such data is processed for the purposes of providing Our professional services and for record-keeping purposes.
e) Transaction data:
We may process information relating to transactions, such as bank account details, contact details, or transaction data in relation to payments made by Us to you or by you to Us. This may include your contact details, or any bank account or sort code information provided for the purposes of making payment, as well as transaction details (such as POs or invoices). The transaction data may be processed for the purpose of supplying or receiving and administering the relevant services and keeping proper records of those transactions, and for making and receiving payments.
f) Personal data We obtain from others:
Your personal data may be provided to Us by someone other than you—for example, by your employer, by an organisation with whom you and We are both dealing, or by someone who wishes to refer you to Us or vice versa. Normally this data will be correspondence data, enquiry data, or project data as described above, and will be processed by Us for the purposes described above.
We will only process personal data on a lawful bases and in accordance with Article 6 of the GDPR:
- Consent, where you have given your explicit consent for Us to process your data for a specific purpose;
- Contract, where the processing is necessary for a contract you have with Us, or because you have asked Us to take specific steps before entering into the contract;
- Legal obligations, where the processing is necessary for Us to comply with the law; and
- Legitimate interest, where the processing is necessary for Our legitimate interests or the legitimate interest of a third party.
Your rights
There are certain rights which are summarised below. Further guidance can be obtained from the Information Commissioner’s Office (www.ico.org.uk) and Berlineer Beauftragte Für Datenschutz und informationsfreiheit (www.datenschutz-berlin.de).
a) right to be informed;
b) right of access;
c) right to rectification;
d) right to erasure/to be forgotten;
e) right to restrict processing;
f) right to data portability;
g) right to object;
rights in relation to automated decision making and profiling.
Further, you have the right to complain to a supervisory authority.
You may exercise any of your rights in relation to your personal data by written notice to us at the address below.
Providing your personal data to others
We may disclose your personal data to Our insurers and/or professional advisers as necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
We may disclose personal data to Our suppliers or subcontractors in connection with the uses described above. For example, We may disclose:
a) any personal data in Our possession to suppliers that host the servers on which Our data is stored. In Our case, these suppliers are Microsoft Ireland Operations Ltd (who provide Microsoft 365, and who host all Our emails, documents and contact information) and NetSuite Ltd (who provide Our enterprise management system which hosts project-related emails, documents and contact information);
b) correspondence data to suppliers which host email campaigns or send or receive correspondence on Our behalf (such as Active Campaign, Mailchimp, WordPress or Zapier in relation to enquiries received through Our site);
c) transaction data and billing contact details to Our accountants; and
d) transaction data and other relevant personal data to third parties for the purposes of fraud protection, credit risk reduction and debt recovery.
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 and applicable law.
In addition to the specific disclosures of personal data set out in this section, We may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which We are subject to, or in order to protect your vital interests or the vital interests of another person.
If any part of Our business or operations is sold or transferred to, or integrated with, another organisation, your personal data may be disclosed to that organisation.
Data security
We have in place appropriate security measures to prevent your personal data 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 officers, employees and freelancers who have a business need to know. They will process your personal data only on Our instructions and they are subject to a duty of confidentiality.
We have 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.
Retaining and deleting personal data
Personal data that We process for any purpose or purposes shall not be kept for longer than is necessary or required by law.
We will retain and delete your personal data as follows:
a) usage data (which is anonymised, and not personal data) may be retained by Us indefinitely;
b) enquiry and correspondence data which does not relate to a business relationship with Us will be retained for the period of the enquiry or chain of correspondence and then deleted after 12 months;
c) project and transaction data, and enquiry and correspondence data which relate to a business relationship with Us will be retained for six years after delivery of the relevant service or transaction or the end of the relationship.
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. For example, certain project and transaction data will be retained for longer than six years in order to comply with HMRC or other tax reporting obligations.
About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. A ‘persistent’ cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a ‘session’ cookie will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that We store about you may be linked to the information stored in and obtained from cookies.
Our Site uses category one and category two cookies. Category one cookies are essential in order to enable you to move around the website and use its features. Category two cookies collect information about how visitors use Our Site—for instance, which pages visitors go to most often. All information these cookies collect is aggregated and therefore anonymous. Category two cookies enable Us to use Google Analytics for analysing the use of and improving the Site. Google Analytics gathers information about website use by means of cookies. The information gathered relating to the Site is used to create reports about the use of the Site. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can obtain up-to-date information about blocking and deleting cookies via the support pages made available by your browser operator.
Third parties and security
The site contains links to third-party websites and refers to third-party service providers and other entities. If you follow a link to any third-party website or deal with any third party entity referred to on the site, then you should note that these third parties may have their own privacy and cookie policies, and that We are not responsible for their use of any personal data which you may provide to them. You should ensure that you have read and understood any relevant policies.
Although We do Our best to ensure the security of personal data provided to Us (and to use only reputable service providers), any transmission of data via the Internet is by its nature insecure and We cannot guarantee the security of any personal data you provide to us.
People who download our content
When you complete a form to download one of Our guides or sign up to an e-course, We will ask you to provide Us with your first name, company name and email, before We email you a link to access the content you requested. Your information will be held for two years before We contact you to obtain consent for continued communications.
Once you have shared your details with Us, and have opted to receive further information, We may contact you with further information, such as related news and content. We will only contact you if We believe that doing so will be of legitimate interest to you and Oxera.
We use a third-party provider, Active Campaign, to deliver Our marketing emails containing information closely related to the subject of your download. We gather statistics around email opening and clicks using industry standard technologies to help Us monitor and improve Our marketing emails. For more information, please see Active Campaign’s Privacy Policy.
In addition, We may promote content and services to you while using third-party platforms such as LinkedIn and Facebook.
Amendments
We may update this Policy from time to time by publishing a new version on the site. We will notify you of material changes to this Policy using the contact details you have given us, but also recommend that you check occasionally to ensure you are happy with any changes to this Policy.
Oxera Consulting LLP, is a limited liability partnership registered in England no. OC392464, registered office: Park Central, 40/41 Park End Street, Oxford OX1 1JD. Our sister company, Oxera Consulting GmbH, is registered in Berlin no. HRB 148781 B.
Oxera is the registered as a data controller in the Data Protection Register of the UK Information Commissioner’s Office under registration numbers ZA132563 (Oxera Consulting LLP) and ZA132567 (Oxera Consulting GmbH).
How to contact us
We have appointed a Data Protection Officer. Any questions concerning this privacy policy or data protection can be sent marked for the attention of the Data Protection Officer to:
Oxera Consulting LLP, 40/41 Park End Street, Oxford OX1 1JD
Tel: +44(0) 1865 253012
Email: [email protected]
Effective: 2021