Data Protection and Privacy Policy

Background
OCL Digital Ltd (“We”, “Us”, “Our”) understand that protecting your privacy and data is important and we declare that we care about how your personal data is used by us.

We respect and value the personal information and data of all of our customers, employees and stakeholders.  

We are committed to protecting and respecting personal data and we confirm we will only collect and use your personal data in ways prescribed by data protection laws and regulations and as described herein, and in such a way that is consistent with our obligations to you and your data privacy and protection rights under the law.

About us
OCL Digital Limited is a limited company registered in Gibraltar under Company Number 117860.

Registered Office: 5 Secretary’s Lane, GX11 1AA, Gibraltar

Registered with the Information Commissioner’s Office (registration number ZA459972)

About this Privacy Policy
This Privacy Policy explains in detail how we manage your personal data, i.e. how your personal data is collected, how it is held and stored and how it is processed.

It also sets out your rights under the applicable law relating to your personal data.

What Is Personal Data?
Personal data as defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) is ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

In simpler terms, personal data is any information about an individual that enables them to be identified. Personal data incorporates obvious information such as an individual’s name and contact details, but it also comprises information which is less obvious such as online identifiers including location data, IP addresses, ID numbers, and so on.

Rights of Individuals
Under the GDPR, individuals have extensive data protection rights.  We ensure we work to defend and promote these rights as follow:

  • The right to be informed about how we collect and use your personal data. This Privacy Notice should inform you of everything you need to know, but please do not hesitate to contact us to discover more about your rights or if you have any queries about how we uphold your rights

  • The right to access any personal data we hold about you

  • The right to request that your personal data be rectified or completed if any of your personal information we hold is inaccurate or incomplete

  • The right to be forgotten.  You have the right to request that we delete or otherwise destroy any personal data that we hold about you, (subject to certain exceptions, regarding legal, contractual or tax obligations or provisions)

  • The right to restrict any processing of your personal data

  • The right to object to us processing your personal data for a particular purpose or purposes that you have not agreed to

  • The right to data portability, for example, if you have provided personal data to us directly, and we are processing this data using automated means, with your consent or for the performance of a contract, you can request a copy of that personal data in a simple portable format.  This is a popular way to re-use your data with another service provider for example price comparison websites

  • Enhanced rights and protection relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about how we use your personal data or exercising your rights as outlined above, please contact us.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about how we use your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

Personal Data We Collect
We collect the following personal data in various ways, mainly according to your connection with us as follows:

  • Title (e.g. Mr, Mrs, Ms etc)

  • Names

  • Date of birth

  • Address

  • Gender

  • Telephone numbers

  • Email address

  • Preferences and interests

  • Demographic information

  • IP Address

  • Cookies

We have no intention, knowingly or deliberately, to collect personal data from children under the age of 18, either for registration purposes or for marketing campaigns.

How we collect your personal data:
We use various methods to collect data as follows:

  • When you fill out a website form on our website or on one of our affiliate or supplier websites

  • When you communicate with us via  a competition or a prize-draw entry

  • When you actively provide your personal data on any aspect of our website

  • When you contact us direct via email, telephone, social media, in writing, or any other communicable means

  • When you sign up or subscribe to any of our services in order to receive communications or notifications from us about our products and services.  For example signing up to our newsletter, or direct messaging through social media

  • When you take part in our surveys, market research campaigns, prize draws, competitions, via the website or affiliate or suppliers website.

How We Use Your Personal Data
In line with the GDPR, we are obliged at all times to have lawful basis for using any personal data.

Lawful basis allows us to manage personal data to carry out the performance of a contract with you, or because you have consented to our use of your personal data, or because it forms part of our legitimate business interests to use your personal data.

Lawful basis also relies upon personal information collected as necessary to manage our customer accounts and progress claims.

We ensure at all times that the information we collect and hold is stored securely within an encrypted database.

Protecting personal data is something we take very seriously and will only ever share data via secure systems with relevant affiliates in the interest of our customers, in order to progress applications, accounts and conclude claims.

There may be occasions when we may be legally obliged to share data with regulatory bodies or authorities, including the Financial Ombudsman, Ministry of Justice, the Information Commissioner’s Office and the Legal Ombudsman.

We may process your personal data for one or more of the following purposes according to our legitimate interest basis and communicated according to whatever method of consent you have provided to us:

  • To determine whether any of the customers or approved affiliates we work with  have relevant services, products or special offers that may be of interest to you based on your supplied preferences to us

  • To manage the participation by you in our promotions and draws on other sites owned by us, such as you supplying registration information and details

  • With your consent, we will convey your data to our trusted affiliates, partners and clients. You have the right to object to this processing at any time by contacting us accordingly

  • To improve our website and personalise our services with you in mind.  This may result in revisions in the way we market directly to you, or communicate with you about relevant offers or products that may be of interest to you based on your preferences supplied to us

  • Depending on what personal data we hold and consent provided by you we may convey your personal data to website sponsors, brand partners, affiliates (third parties) who may in turn contact you for the purpose of direct marketing

  • For analysis exercises. Whenever we perform data analysis this data is aggregated and whenever necessary anonymised in line with GDPR principles and the ICO code of practice. These exercises are for marketing purposes solely.

  • Personal data is either processed by ourselves or through a third party data processing organisation.  We take all effective measures to ensure that any third party data processing is carried by organisations who have in place the same principles and compliance requirements as set out in this Data Privacy Policy and in line with the principles of Data Protection laws and regulations.  

  • Data such as email addresses, telephone numbers or location data will only be released to third parties where you have provided us with your explicit consent, at the time of registering your interest on our website (or any of our affiliated or supplier websites) ensuring transparency.  We ensure that you fully understand what it is you are consenting to.

  • If you consent to a call from one of our affiliates, sponsors or brand partners this will override your Telephone Preference Service (TPS).

Legitimate Interest
The definition of legitimate interests include your interests as well as our interests. These interests  include individual interests, commercial interests, or extensive societal benefits. However we are required to identify a legitimate interest and show that the processing is necessary to achieve these interests; and perform a balancing act  against your rights, interests and freedoms.

Marketing
With your consent and/or legal permission, we may use your personal data for the purposes of marketing.  This may include contacting you by email, telephone, text message or post, with relevant information on our products and services, information regarding special offers, industry news and so on.   We will not send any unlawful marketing or spam.

We are fully committed to ensuring the privacy and protection of your rights and to comply with our legal obligations under the GDPR, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any other relevant Data Protection legislation.  At all times you have the opportunity to easily opt-out.

We only ever convey your personal information to third parties where you have given explicit consent to do so. However, to prevent fraud and ensure data accuracy we are required to submit your information for verification and filtering.  We will always inform you of any third parties used for this purpose.

Personal Data Retention Periods
In line with the GDPR and Data Protection laws and regulations, we will not keep your personal data for any longer than is necessary, and in light of the purposes for which it was first collected. The following retention periods apply:   

Following an enquiry to our website or one of our suppliers websites we will retain your contact details for a period of 6 months.

After a retention period of  6 months your personal data is placed in a suppression file for a further 18 months.  This is to ensure that you are not contacted or receive any further communication from us or from any of our affiliated partners in case your information has been supplied to them previously.

These retention periods enables us to provide relevant services to you, and allow us to conform with our legal obligations. We will ensure that technical, management and organisational precautions are in place to prevent any loss, theft, mishandling or alteration of your personal information.

We store all personal information provided to us on secure servers that are subject to strict access and security requirements.

Cookies Explained
Our websites use cookies to collect information. Cookies are small data files which are placed on your computer or other mobile device (such as laptops, mobile phones or tablets), when you browse our websites. Cookies remember and store data whenever your computer or device access our websites.

We do not use cookies to gather or record personal information such as names, addresses or other contact details.

Cookies stored on your computer or mobile device when you access our websites are set by us and associated third parties for marketing purposes only and are unable to collect any personal data from which they would be able to identify individual users, clients or customers.  The main purposes for which cookies are used on our websites are:

  • For technical purposes for effective operation of websites.

  • For marketing purposes, particularly targeted updates and banner advertisements.

How to Manage or Disable Cookies
You have the power to disable and manage cookies.  To do this you will need to change your website browser settings and this will depend upon your browser.  Go to your browser settings to locate the privacy options and follow the relevant instructions on how to manage/disable cookies for your browser.  Please do not hesitate to contact us if you have any queries on how we use cookies and how you can manage or disable them. Please be aware that if you chose to disable Cookies our websites may not operate effectively.

Where we Store/Transfer Personal Data
We may store or transfer personal data to third countries, i.e. countries that do not form part of the European Economic Area, (The EEA).

The “EEA” consists of all EU member states, with the inclusion of Iceland, Norway, and Liechtenstein.

These third countries may not have the same level of data protection laws that are as robust as those in the UK and/or the EEA.

Because the security of your personal data is crucial to us we wish to protect it as securely as possible.  Hence we have taken appropriate measures as instructed by the GDPR, in order to ensure that your personal data is handled by third countries just as safely and securely as it would be within Europe, the UK and as per the principles laid down via the GDPR.  We have done so by carrying out appropriate and thorough due diligence tests, and having contractual agreements in place that allow us to transfer your data legally and with adequate protection that enables you to exercise your rights appropriately and as entitled.

Sharing of Personal Data
If we wish to share any or all of your personal data with selected third parties  we will always ask for your explicit consent before doing so. It will only ever be your decision to allow us to share your personal data.

There may be circumstances where we may legally be obliged to share certain personal data information.  For example, we may be compelled to share individual data where we are involved in legal proceedings, or in circumstances where we are required to comply with a contractual or other civil obligation, to comply with an order from a court, or if  instructed to share data with a government authority.

In any circumstance where your data is required by any third party as described above we will take all the necessary steps to ensure that your personal data is handled in a safe and secure manner in line with data protection laws and regulations and in accordance with your rights, our legal compliance obligations, and any third party obligations under the law.

Data Subject Rights
You have the right to request from us whatever personal data we hold about you.  This is referred to as a “Subject Access Request” and we are required by law to act upon any such request.

We ask that Subject access requests are made in writing and sent to us via email or postal addresses.  We will require validation of identity before acting upon a Subject Access Request.

We do not usually charge for Subject Access Requests, however the GDPR provides a stipulation that such requests should not be “manifestly unfounded or excessive”.  In this respect an administrative fee may be charged in the event of repetitive Subject Access Requests.

We aim to respond as quickly as possible to Subject Access Requests, i.e. within 28 days.

We will provide a complete confirmation of data that we hold on you.  Where a Subject Access Request is complex with vast amounts of complicated information, more time may be required to fulfill the request.  In this event we will contact you to request up to a maximum of three months to fulfill your request.

At all times we will endeavour to keep you informed of the progress of the Subject Access Request.

How to Contact Us
You can contact us about anything regarding your personal data and any issues you have about data protection, including applications to make subject access requests.

Contact us via our main trading address:

OCL Digital Limited
World Trade Center
6 Bayside Road
1st Floor – Unit 1.02
Gibraltar
GX11 1AA

Or email us on: admin@ocldigital.com

Changes To this Privacy Notice.
We may amend or change this Privacy Notice as required from time to time in line with changes to our business or legal updates to data privacy and data protection.

Any changes or alterations will be made available by the posting of the new “current version” on our website.

Please ensure you check this page periodically to ensure you are satisfied and happy with any changes.  Any changes or alterations affecting you personally, will be communicated directly to you.

How to Refer any Concerns to the UK Data Protection Supervisory Authority
OCL Digital Ltd are regulated by the Information Commissioner’s Office (ICO) in respect of our legal obligations to protect your personal data. You have the right to raise any concerns with the ICO about how we store, manage, process your data.  The ICO will investigate this on your behalf. Please note that the ICO will only investigate complaints made within three months of your last contact with us.

You can contact the ICO through their website: https://ico.org.uk or by telephone: 0303 1231113.