We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by writing to The Marketing Team at the address notified above.
We have set out below, in a table format, a description of all 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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Profile, Technical and Usage 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 Services and offers may be relevant for you and send to you through our marketing messages.
You will receive marketing messages from us if you have requested information from us or purchased Services from us and you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us or unsubscribing from our marketing list.
We use analytics cookies to collect information on website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering our website from another website, the address of that web site). This information on its own does not identify an individual but it does provide us with statistics that can be used to improve our website.
The browsers of most computers, smartphones and other web-enabled devices are usually set up to accept cookies. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different, so check the "Help" menu of your browser to learn about how to change your cookie preferences. However, please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain cookies off, it may affect how our websites work and certain functionality may not work. More information about cookies can be found on allaboutcookies.org.
- Understanding how you use the Sites and Service: we use a range of services to understand how you use our Sites and Service including Google Analytics and/or Clicky Web Analytics. This helps us continually improve our Services and deliver more relevant and useful content to you.
- Behavioural and retargeting: Origo collects data about your activities that does not personally or directly identify you when you visit our Sites. This information may include the content you view, the date and time that you view this content, the Services your use or purchase, or your location information associated with your IP address. We may use the information we collect to occasionally provide you more relevant advertisements (referred to as “retargeting”). We collect information about where you saw the ads we serve you and what ads you clicked on.
In order to accept cookies when browsing our Sites, simply accept cookies in the message that appears on your screen. You can disable cookies by adjusting your browser settings. Each browser is different, so check the “Help” menu of your particular browser (or your mobile phone's handset manual) to learn how to change your cookie preferences. The “Help” menu on the toolbar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether.
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 notify you and we will explain the legal basis which allows us to do so.
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.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Where Origo is the processor and shares personal data in performance of a contract.
- Public databases and credit reference agencies who assist in providing the Services.
- Service providers who provide payment, marketing, IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based within the EU who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances, especially in the prevention of money laundering and fraud.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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.
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.
Third Parties where we act as an introducer
Where we are acting as an introducer to a third party, the use of any of your data provided to that third party will be as stated in their terms and conditions of business.
6. International transfers
Some of our external third party suppliers are based outside the European Economic Area (EEA). 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- 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 similar protection to personal data shared between the EEA and the US. For further details, see European Commission: EU-US Privacy Shield.
7. Data security
The security of your personal information is important to us. We follow best practice industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Commonly referred to as “bank-level” security, this means we use the same encryption standards that you would have with your own bank. We also routinely run security audits to ensure we meet these standards at all times.
When you enter sensitive information (such as bank credentials or a credit card number) you should always be encrypted using secure Transport Layer Security (TLS). We will always use such encryption.
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.
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.
8. Data retention
How long will you use my personal data for?
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. In some cases we may retain your personal data for at least 7 years to meet our regulatory compliance requirements or as needed to provide to you the Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. If your account is deleted, all personal information will be removed from our systems except for any Transaction Data, Technical Data and records required to comply with our legal obligations, resolve disputes and enforce our agreements.
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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Access to information: You have the right to request a copy of the information we hold about you.
- Ensuring accuracy of information: We want to make sure that your personal information is accurate and up-to-date. You may ask us to correct or complete information that is inaccurate or incomplete.
- Right to erasure: You may have a right to erasure, which is more commonly known as the ‘right to be forgotten’. This means that in certain circumstances you can require us to delete personal information held about you.
- Ability to restrict processing: You may also have the right to require us to restrict our use of your personal information in certain circumstances. This may apply, for example, where you have notified us that the information we hold about you is incorrect and you would like us to stop using such information until we have verified that it is accurate.
- Right to data portability: You may have the right to receive personal data we hold about you in a format that enables you to transfer such information to another data controller (e.g. such as another service provider).
- Review by an independent authority: You will always have the right to lodge a complaint with a supervisory body, including the ICO as listed above.
- Preventing direct marketing: We do not sell your personal data. From time to time, we may send emails containing marketing information and other news about us. This is considered direct marketing. We will always ensure that we have your consent to use of your personal data for direct marketing.
- Objecting to other uses of your information: You may also have the right to object to our use of your information in other circumstances. In particular, where you have consented to our use of your personal data, you have the right to withdraw such consent at any time.
If you would like further information on how you can exercise these rights, please email us at firstname.lastname@example.org.
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 to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.