Last updated: 14 July 2023
Owner: Legal Team
1. Introduction
We value your privacy and are committed to protecting and processing your personal data responsibly. This Privacy Policy sets out how we use and protect your personal data when you visit this website, visit our app or communicate with us.
By providing personal data to us, you consent to our collection, handling, use and disclosure of your information in accordance with this Privacy Policy.
Disclaimer: This website is not intended for children and we do not knowingly collect data relating to children.
2. Data Controller
OTA Insight Ltd., with company registration number 8178250, referred to as OTA Insight, acts as the data controller of your personal data. Our registered address is Suite 8, 59 St. Martin’s Lane, WC2N 4JS London, England.
3. Data collected 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 as follows:
| Identity, Profile, Contact & Contract Data: |
including but not limited to first name, last name, company details, department, function or title, username or similar identifier, billing address, email address, telephone number. |
| Financial & Transaction Data: |
bank account, payment card details and other details of software and services you have purchased from us. |
| Technical Data: |
internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. |
| Usage and Experience Data: |
information about how you use our website, products and services, customer service |
| Marketing and Communications Data: |
your preferences in receiving marketing from us and our third parties and your communication preferences. |
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We do not collect any information about criminal convictions and offences.
Failure to provide personal data required to collect by us either as determined by law or under the terms of an agreement may result in our inability to perform under our agreement.
Third-party links: This website may include links to third-party websites and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control these links or websites and are not responsible for their data processing.
4. How we collect your personal data
We will only process your personal data where we have a legitimate basis to do so. Most commonly we will process your personal data in the following circumstances:
- The performance of an agreement we have entered into with you (or are about to enter into);
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do no override our interests;
- Compliance with a legal obligation;
- Your consent
We use different methods to collect data about and from you including but not limited to:
| Direct interactions |
You may give us your Identity, and Contact Data by filling in contact forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
● use our Products & Services
● enquire about our software or services;
● create an account on our website;
● subscribe to our Services, communications or publications
● request marketing communications to be sent to you; or
● give us feedback or interaction with our Customer Services |
| Automated technologies or interactions |
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details. |
| Third parties or publicly available sources. |
We will receive personal data about you from various third parties and public sources such as Identity and Contact Data from publicly available sources such as Companies House, your company’s website or Linkedin. |
5. Purpose of processing your personal data
We may process your personal data for a variety of reasons that are justified and are allowed under the applicable data protection laws. These form the legal basis under which we process your personal data.
In general we process your personal data for the following purposes:
- To deliver our Services and enable you to access and use our Services;
- To improve our Services and your overall user experience;
- To contact and communicate with you;
- To administer and improve our website;
- To prevent and address technical problems, and maintain the security of the Services;
- To help us understand traffic patterns, and analyze how you use the Services;
- For internal record keeping;
- For advertising and marketing, including to send you information about our products and services;
- In connection with a merger, acquisition, reorganization or similar transaction;
- When required or permitted by law, to take appropriate legal action, or to respond to legal process;
- For any other purpose with your consent.
If you have previously given consent to our processing of your data you can freely withdraw such consent at any time. You can do this by emailing us at privacy@otainsight.com.
If you do withdraw your consent, and if we do not have another legal basis for processing your information, then we will stop processing your personal data. If we do have another legal basis for processing your information, then we may continue to do so subject to your legal rights.
Sensitive Data
We do not collect any sensitive data about you (e.g. racial, ethnical, political, religious belief, trade union membership, genetic data, biometric data, health data, etc .. except in circumstances where we have your express consent or when we have to comply with the law.
Children
Our Products & Services are not intended for children.
6. Disclosure of your personal data
We may have to share your personal data or other information about you in a variety of ways in connection with the purposes as set out in Section 5 of this Policy.
We may share your personal data or other information with the following parties:
- other members of the OTA Insight Group
- with companies that provide services to OTA Insight
- with other third-party service providers that have integrated with our products and services.
7. International transfers of personal data
We share your personal data within the OTA Insight Group. This may involve transferring your data outside the UK, European Economic Area or Switzerland. Many of our external third parties are based outside of these jurisdictions so their processing of your personal data will involve a data transfer outside of these jurisdictions.
OTA Insight complies with laws on the transfer of personal information between countries to keep your personal information protected, wherever it may be. Any transfer of personal data to a third country, which means outside the European Economic Area (EEA) or Switzerland, shall be subject to one of the following safeguards:
- an adequacy decision by the European Commission (if any); or
- a data transfer agreement, which shall contain the standard contractual clauses, as referred to in the 'European Commission decision of 5 February 2010 (Decision 2010/87/EC); or
- binding corporate rules, as implemented by OTA Insight.
Whenever we transfer your personal data outside of the jurisdictions mentioned above we ensure a similar degree of protection afforded to it by ensuring at least one of the following safeguards is implemented:
- We will aim to only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use providers or provide Services in the US we may transfer data to the US. In such an event we will ensure that they provide similar protection to personal data shared between Europe and the US for example through standard contractual clauses as provided by the European Commission.
8. Data Security
We have implemented several appropriate technical and organizational measures to protect your personal information
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.
9. Data retention
We will only retain your personal data for as long as necessary to fulfill 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.
In some circumstances we may anonymise your personal data (so that it can no longer be linked to you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact us at privacy@otainsight.com.
You have the right to:
- Request access to your personal data ( a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to confirm that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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 withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit for response
We engage ourselves to respond to all legitimate requests within one month. In case your request is of a complex nature we will keep you informed on the status of your request and the estimated time for response.
11. Contact us
If you have any questions or concerns about this policy or our privacy practices, you may email us at privacy@otainsight.com.
12. Changes to this Policy
We reserve the right to make changes to this Policy. In the event that these changes affect our obligations, or your rights, we will inform you about the changes in advance.
