Privacy Policy

Optimity Limited, is a managed service provider.

Your privacy is our priority. So, on this page we’ve outlined what information we collect about you, how we use it and where we store it.

We’ve tried to make everything which follows as clear and as simple as possible, but if you have questions, you can contact us, and we’ll be happy to help. (See the “Contact Us” section below.)

Purposes of this policy

This General Privacy Policy aims to give you information on how Optimity collects and processes personal data:

• collected by us through your use of this website, including any data you may provide when you create an account with us, sign up to our blog, sign up for one of our services, download one of our guides, download a case study, take part in a competition, submit a support ticket, start a live chat or otherwise contact us;
• collected by us through the storage of cookies on your device;
• provided to us in the provision of our services to the persons or companies who engage us and the end users of our services (our ‘Customers’); and
• relating to other persons or companies having a business relationship with Optimity, such as our suppliers and agencies we do
  business with.

Any information that we collect is subject to our Privacy Policy in effect at the time that information is collected.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Changes to this Privacy Policy

We may change this policy from time to time. Although we will strive to ensure that any such changes are small, and we will inform you and, if appropriate, seek your consent if we intend to materially change the way in which we use your data, we recommend that you consult this Privacy Policy regularly for updates.

Scope

This policy describes our general practice and procedure for collecting, using and disclosing information about employees, agents, officers, workers and contractors of our customers, those of our commercial partners and visitors to our website (Individuals).

Collection

We collect, process and retain personal information from Individuals when they interact with our website and in connection with the provision of our services to our Customers.

Use

We use the information collected from you when you interact with our website to improve the performance of our website. When you complete one of the forms on our website, we use the data we collect from you to deliver marketing information which we think will be of interest to you based on the information provided to us. When you enter into a live chat or submit a support request, we process the information submitted to resolve your support query and to improve our services.

Your rights

You have certain rights regarding our processing of your personal data. Further information on the rights you may have, and how to exercise such information can be found here:

Disclosure and security

We may disclose your personal data to other companies within the Optimity group, to third party service providers and where we otherwise have a legal right to do so.

We protect your information using measures that reduce the risks of loss, misuse, unauthorised access, disclosure and alteration.

Questions

If you have a question about this Privacy Policy, please contact privacy@optimity.co.uk

The data we collect about you

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer
different types of data about you:

• Identity Data. We process information about our business contacts using a customer relationship management (CRM) platform. Personal Information is collected and added to our CRM platform by Optimity staff and includes: name, email address, job title, company name, company size, industry, jurisdiction and other business contact information.
• Personal Information may also be collected when you submit a form on the Optimity website and when you provide it to us in connection with the provision of our services.
• Browsing Data. When you visit our website, we track traffic data, location data, any weblogs and other communication data between us, and the resources that you access. We also track location of usage, frequency of access, data used from and details of the person who logs in to use our products and services.
• Technical Data. Whenever you visit our website, we collect your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, Operating system (type and version) and information about device (type and version) you use.
• Marketing Data. including your preferences in receiving marketing from us and our third parties, your communication preferences and information on what you view, click on and access in and through our marketing emails, text messages and push notifications.
• Cookies. Like many websites, we use “cookies” and similar analytics-driven technologies. See the “Cookies” section below and our Cookies policy (available here) for further information on our use of cookies.

Where we combine Identity Data with the other data we collect from you, we treat all of that combined data as personal data.

How is your data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. Data you provide to us directly includes Identity Data, including when you complete a form on the Optimity website, Browsing Data where this comprises direct conversations and other communications between you and us and Marketing and Communications Data when you update your preferences. We may also record calls or video conferences that we have with you.
• Automated technologies or interactions. As you browse our website, we may automatically collect other types of Browsing Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Social Media Interactions: You may also interact with us by using your social media applications.
• Other Third Parties or Publicly Available Sources: we may receive personal data about you from various third parties and public

sources as set out below:

• Technical Data from analytics providers such as Google, advertising networks and search information providers.
• Marketing Data and Technical Data from online advertising data providers such as Google based outside the EEA
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Profile Data and Marketing Data from social media providers such as Facebook based inside and outside of the EEA
• Identity, Contact and Profile Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EEA.

How we use your data

Use of Identity Data

We may use your Identity Data for contact and communication purposes to contact you in connection with your use of our services, including to provide you with reports and statistics regarding the use of our services and to investigate and resolve support or customer service queries. We may use your Identity Data to send you marketing communications from time to time, to provide you with news about any of our events, and/or other information about us and the services that we provide that we believe may be of interest to you. You can specify your contact preferences when registering to receive communications from us (for example, when you submit a form through the Optimity website) or by subsequently advising us of your contact preferences or managing your email preferences.

Use of Browsing Data and Technical Data

As soon as you visit our website, we begin tracking Browsing Data and Technical Data. This information about your general internet usage helps us to improve our website and deliver a better and more personalised service; for example, we store information about your preferences so that we can recognise you when you return to our site, speed up your searches and customise our site according to your individual interests. We also use it for system administration, such as counting visitor numbers and seeing how they move around our site, enabling us to improve the way our website works. We may also use it to report aggregate information to our advertisers. This data is statistical and does not identify you as an individual.

Use of Automated processing

We do, from time to time, process personal data about Individuals in an automated way to evaluate certain personal aspects about such Individual, including to enable us to analyse and make predictions about their interests and how they are likely to interact with our business and which of our services may be of interest to them. This is commonly referred to as profiling and it is our way of providing Individuals with a more bespoke customer experience based on how we think the Individual will engage with us. We may choose to send a particular marketing communication to an Individual based on our calculation of which of our services may be of most interest to them.

The personal data about you that we process for profiling purposes includes your Identity Data, your Contact Data and your Marketing Data.

Whilst our automated processing would constitute profiling under the EU data protection legislation, no decisions are made solely as a result of such automated processing.

Our basis for processing your data

We will only use your personal data when the law allows us to. We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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
To ensure content from our website is presented in the most effective manner for you and your computer	Identity Data Browsing Data Technical Data Cookie Data	(a) Necessary for our legitimate interests (to ensure a smooth-running customer-facing website)
To ensure that we are providing a great service and meeting expectations in how we deliver information to you. Which may include the recording of calls with you.	Identity Data Technical Data	Necessary for our legitimate interests for training and record keeping purposes.
To provide you with information, products or services that you request from us or which we feel may interest you	Identity Data Browsing Data Marketing Data Cookie Data Technical Data	(a) Legitimate interest (b) Your consent
To carry out obligations arising from any contracts entered into between us and your employer	Identity Data Browsing Data Technical Data	Necessary for our legitimate interests (to manage our relationship with our customers and perform our obligations under such contracts)
To allow you to participate in interactive features of our service, where you choose to do so	Identity Data Browsing Data Marketing Data Technical Data	Necessary for our legitimate interests (to offer interactive features and communication channels with you)
To notify you about changes to our service	Identity Data	Necessary for our legitimate interests (to manage our relationship with you and keep you properly informed)
To see if services accessed via our website are used in accordance with the terms and conditions applicable to the services including to detect and prevent account abuse	Identity Data Browsing Data Technical Data	Necessary for our legitimate interests (to identify and resolve problems with the use of our website or our services)
To process communications between you and us, whether emails, live chat messages or contact forms	Identity Data Browsing Data Technical Data	Necessary for our legitimate interests (to support you as a visitor to our website and resolve problems you encounter with our website or in your use of ouse services)
To process information provided to us at the point of registration, post-registration, and during any surveys or form completions	Identity Data Browsing Data Technical Data	Necessary for our legitimate interests (to identify users, track usage and improve our service)
To process information collected from satisfaction surveys	Identity Data Browsing Data Technical Data	Necessary for our legitimate interests (to improve our service levels and product offerings and to benchmark our market fit as a business)
To contact you where we believe that our services may be of interest to you	Identity Data Browsing Data	(a) Necessary for our legitimate interests (to increase the number of Customers using our services) (b) Your consent
To provide information to our Customers regarding use of our services by Individual Users, including the provision of reports and statistics	Identity Data Browsing Data Cookie Data	Necessary for our legitimate interests (to manage our relationship with our customers and perform our obligations under such contracts)
To provide our third party advertising partners with information regarding your interaction with our website to enable them to (i) display adverts regarding our services when you visit a third party website or (ii) provide us with information on audiences of users who may have similar attributes to you and may be interested in our services.	Cookie Data Identity Data	You consent

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 explain the legal basis which allows us to do process personal data for such unrelated purpose.

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.

Marketing

We always want you to be aware of how we use your data, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Technical, Usage and Marketing Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which of our services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition, registered for a promotion or when you complete a form on our website to download some of our content and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Optimity group of companies for marketing purposes. When a visitor to our website does not submit a form or register for one of our services, we may engage a third party advertising partner to ask them to deliver adverts to you regarding our services which we feel may be of interest to you when you visit a third party website.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a when you purchased services from us or when you have provided us with further information in connection with the use of our services, such as when you submit a support ticket or enter into a live chat on our website.

Cookies

A cookie is a small file containing a string of characters that is sent to your device when you visit a website. When you participate in our research, we and/or our third-party partners may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them or they expire – usually after 1 year). Further detail in relation to the cookies that we and/or our third-party partners may use are set out in our cookies policy here.

We and our partners use cookies to provide you with the best possible user experience, and also to track your online activity for the following purposes:

• To improve your experience on our website. As discussed elsewhere in this Privacy Policy, we track your browsing activity, patterns and preferences to enable us to provide you with the best user experience; for example, to customise our content (such as language) to your location.
• To measure user engagement on our website. We track the activity of users to our website to understand which parts of our website are most popular with visitors to our site. We may use this information to understand which of our services may be of interest to you.

Important note about cookies: When you visit our website, we will ask you to consent to our and our third-party partners’ setting and reading cookies from your browser.

We always want you to be in control of the information you share with us, and there are a number of ways that you can remove or block cookies at any time, including by following the help file directions in your internet browser. But if you want to tell us right now that you don’t want us to use cookies, then you can opt-out by emailing opt-out@optimity.co.uk.

When you opt out, we delete the existing values in our cookie on your device and replace them with an “opt out” value which tells our server not to continue to track your behaviour, and we will ignore all subsequent requests coming from your browser. Please note that if you block cookies, our opt-out process may not function properly. Please also note that if you choose to opt-out now, but then at some point later you decide to delete, block, or otherwise restrict cookies, or if you use a different device or internet browser, you will need to renew your opt-out choice.

If you decide you want to opt-out of our cookie process at some point in the future rather than now, you can always email opt-out@optimity.co.uk.

Disclosures of your personal data

We may disclose your data to third parties such as:

• Other members of our group of companies;
• Authorised third-party service providers who provide IT and administration services to us to help us to provide our services, including the provider of our CRM system and other software solutions used by us in the provision of our services;
• Other third party data processors for analytics and communication purposes, to help us to provide our services;
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets; or where we may seek to acquire other businesses or merge with them; and
• Third parties where we are under a duty to disclose or share your personal data in order to comply with any legal obligation.

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. 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.

Please note that although we will not use the information that we receive, or any Technical Data, to identify you, we can never fully know what other information a third party holds about you already, and it may be that third parties are able to link the information we provide to other information that you have previously shared directly with them. For example, third parties such as our clients (and our clients’ own clients) are likely to have databases of their own, and it may be that you have consented to them holding information about you that could allow them to match their records with the data we supply. Similarly, if we share data with social networks, it may be that they can match our data with the other information that you have permitted them to hold about you. Please note that third parties should only lawfully be able to undertake this “matching” if you have given them specific permission to hold and use your data in such a way

International transfers

We share your personal data with other companies within our group. This will involve transferring your data outside the European Economic Area (EEA). Some of our external third-party service providers are based outside the European 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 adequate protection.
• 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 an equivalent level of protection to personal data shared between the Europe and the US.

Data security

We have put 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 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.

Where we have given you, or you have chosen, a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

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 take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. Unfortunately the transmission of information via the internet is not completely secure, and although we will do our best to protect your data, we cannot guarantee the security of your data transmitted to us; and therefore any transmission is at your own risk.

Data retention

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.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstance, you have the right under data protection laws in relation to your personal data:

• The right of access: your right to obtain confirmation as to whether or not personal data are being processed, and, where that is the case, access to the personal data along with details regarding the nature of processing.
• The right of rectification: your right to obtain the rectification of inaccurate personal data.
• The right of portability: your right to receive your personal data in a structured, commonly used and machine-readable format.
• The right to be forgotten: your right to erase 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.
• The right to restrict processing: your right for your data to be effectively ‘frozen’; stored and not further processed.
• The right to object: your right to object to how your personal data is processed where we are relying on a legitimate interest (or those of a third party).

If you would like to exercise one of your rights listed above please send an email to privacy@optimity.co.uk.

Please use the email template below to confirm the right you wish to exercise together with details of the data in respect of which you are exercising such right.

• Subject:
• Body:
• Name:
• The right you would like to exercise
• grounds for your request (where applicable)
• personal data which is subject to the rights request

The EU data protection legislation also contains a right for you not to be subject to a decision made solely on automated processing, which includes profiling. As mentioned above, no decisions are made by us in relation to our use of your data which are based on automated processing without human intervention.

Please note, where we process your information for statistical purposes, certain of the above rights may not be available to you. Please contact us for further information on which of the above rights will not apply to our processing of personal data for statistical purposes.

You have the right, at any time, to make a complaint to the Information Commissioner’s Office (ICO), the supervisory authority for data protection issues in the UK (phone: 0303 123 1113 or at www.ico.org.uk/concerns). However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please feel free to contact us in the first instance using the contact details provided below.

What we may need from you

Where you wish to exercise one of the rights listed above, 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.

Where we are not able to determine with any degree of certainty whether the information requested by you relates exclusively to you, our disclosure of such information to you may pose a privacy risk to a third party (for example, where a cookie is associated with a device used by more than one person). We will assess each request to exercise any of the rights listed above individually on its merits and will disclose the requested information where we are satisfied that such disclosure does not represent a privacy risk to any third party.

Contact Us

If you want to ask us any questions, please get in touch with us at privacy@optimity.co.uk. Or you can write to us at the following address: Optimity IT Limited, Zetland House, 5-25 Scrutton Street, London EC2A 4HJ

Cookie Policy

In connection with the cookies set by Optimity IT Limited, a unique identification number will be stored in or associated with the cookies or related technologies. A cookie is a piece of information placed on your computer’s browser when you visit a website. They are used for a range of purposes, including to remember your identity when visiting a website. Cookies can also track your internet activity, including what pages you visit on a website, to determine the effectiveness of advertising on your behaviour.

Below please find descriptions of the cookies and similar technologies we use, including our tracking cookies. Except for cookies which are essential for this website to work, you can manage the use of cookies and similar technologies by expressing your preferences as set forth below. Please understand that if you exercise your right to opt-out of a cookie, we will place a cookie on your device typically referred to as an “opt out cookie”. If you later clear your cookies, you will also remove this opt out cookie and you will have to renew your choices. To access the opt-out links after you consent, please email opt-out@optimity.co.uk.

Please be aware that the use of cookies is browser-specific. If you use multiple browsers or devices, you will need to modify your preferences on each one.
We use the following types of cookies on our site:

Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site or use a shopping cart.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you and remember your preferences.

Types of cookie	Who serves these cookies	How to refuse
Essential website cookies: These cookies are strictly necessary to provide you with services available through our website and to use some of its features.	Optimity Ltd	Because these cookies are strictly necessary to deliver the Websites to you, you cannot refuse them. To refuse these cookies, please see below under the heading "Controlling Cookies"
Performance and functionality cookies: These are used to enhance the performance and functionality of our website but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.	Optimity Ltd	To refuse these cookies, please see below under the heading "Controlling Cookies"
Analytics and customisation cookies: These collect information that is used to help us understand how our Websites are being used or how effective our marketing campaigns are, or to help us customise our website for you.	Google Analytics LinkedIn Analytics	To refuse these cookies, please see below under the heading "Controlling Cookies" Alternatively, please click on the relevant opt-out link below or email opt-out@optimity.co.uk: - Google Analytics - LinkedIn does not appear to provide an opt-out link for its analytics cookies. For more information about such cookies, please see this page.
Social networking cookies: These cookies enable you to share pages and content that you find interesting on our website on third party platforms. These cookies may also be used for advertising purposes too.	Facebook Connect	To refuse these cookies, please see below under the heading "Controlling Cookies" Alternatively, please click on the relevant opt-out link below: Facebook Connect

Controlling Cookies

You may also refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.If you wish to delete cookies you can do so through your browser, and further information on how to do this can be found here.

EFFECTIVE DATE: 1st November, 2022