Oxentia Ltd (“Oxentia”, “we”, “us”, or “our”) is responsible for your personal data and is the designated “data controller”. We also provide services to clients for whom we are the “data processor”.

Oxentia is a limited company registered in England.
Registration Number: 10537918
Registration Address: 30 Upper High Street, Thame, Oxfordshire, OX9 3EZ, UK

If you have any questions about this privacy statement or how and why we process personal data, please contact Oxentia’s Data Privacy Manager:

Data Privacy Manager
Oxentia Ltd
Buxton Court, 3 West Way
Oxford
OX2 0JB
UK

Email: Dataprotection@oxentia.com
Phone: +44 (0)1865 636 270

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 Data: includes first name, last name, username or similar identifier, date of birth and gender etc.
• Contact Data: includes billing address, service delivery address, email address and telephone numbers etc.
• Financial Data: includes bank account and payment card details.
• Transaction Data: includes details about payments to and from you and other details of services you have purchased from us.
• Communications Data: includes your preferences in receiving marketing from us and your communication preferences (more information in the ‘Your communication preferences’ section below). This includes:
  • Email communications: If you contact us by submitting a message through our website Contact form, we will record your name, phone number, email address, company name, job title and any message you send.
  • Marketing communications: If you sign up to receive the Oxentia Newsletter, we will collect your first name, last name, email address, job title/position and company/organisation name.

We also collect, use and share website usage data, using Google Analytics (more information in the ‘Website analytics’ section below)

Oxentia does not intentionally collect any special categories of personal data (sensitive personal information) about you. The exception to this is the recruitment processes, where sensitive data may be collected, to ensure meaningful equal opportunity monitoring and reporting, and to ensure adjustments may be made in the recruitment process for disability status. Recruitment data will be anonymised within four months of recruitment unless explicit consent is received for Oxentia to keep your personal data. More detail of our candidate privacy notice is located here.

If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

We use Google Analytics to track and analyse web traffic in order for us to improve our website and provide us with essential marketing data (e.g. number of page views to our site in a month). Only anonymous data is stored and we take care to avoid any personal data being sent to Google Analytics. We collect this data under the “legitimate interest” lawful basis.

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:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website and customer experience, informing you about our services and ensuring that our operations are conducted in an appropriate and efficient manner.
• Where we need to comply with a legal or regulatory obligation.
• Where you have consented to receive email marketing communications from us (the Oxentia Newsletter), to provide you with information that we think will be of interest to you about us and our services (see the ‘Your communication preferences’ section below)

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 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, and you have the right to restrict or object to our use of your personal data at any time (see below).

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.

The Oxentia website offers an email update service ‘the Oxentia Newsletter’, allowing users to voluntarily subscribe to receive quarterly updates, news and insight from the Oxentia team.

If you sign up to receive the Oxentia Newsletter, we will collect your first name, last name, email address, job title/position and company/organisation name. By filling out your details and clicking on the ‘submit’ button on the form (found at the bottom of the Oxentia website homepage) you are subscribing to the Oxentia newsletter. You acknowledge that your information will be securely transferred to and stored in Oxentia’s marketing platform MailChimp

You can unsubscribe from the Oxentia Newsletter at any time, by clicking on the unsubscribe link in the footer of our emails or emailing Dataprotection@oxentia.com with your request. You can also use the online preference centre (linked in the footer of our emails) to update your details. If you unsubscribe or ask us to stop sending you marketing emails, we will keep a note of your email address and your request so that we can make sure you are excluded from future email update lists.

Please note that if you tell us that you do not wish to receive marketing emails, you will still receive service emails which are necessary for us to perform the contract we have with you, for example to notify you of a change to an event you are registered for.

Oxentia facilitates online event registration via our website and on occasion third party websites. Personal information may be collected via event registration forms and the type of information collected will vary. Oxentia may share registrant information with third parties in association with the event such as hotels, event organisers (including via third party web sites), trainers etc., however we will never pass your details to third parties in order for them to contact you without your express consent.

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.

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.

Sometimes we use third parties in other countries to help us deliver our services.  In some cases, personal data may be transferred outside the European Economic Area (EEA) and to countries that do not have laws that provide specific protection for personal data.

Whenever we we transfer your personal data out of the EEA, we will ensure the transfer will be under an agreement which fulfills EEA requirements, such as the European Commission approved standard contractual clauses (available here).

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.

We will actively review the information we hold and when there is no longer a customer, legal or business need for us to hold it, we will either delete it securely or in some cases anonymise it.

You may request us to hold data for you (even if we no longer require it) in circumstances where you might need it to establish, exercise or defend legal claims. Please contact dataprotection@oxentia.com should such a need arise.

You have the right to request access to, and update or correct, personal data held by us as a data controller. You can email email us to exercise this right. We aim to respond to any requests for information within one month and will make corrections based on your updated information. If the request is particularly complex we may have to extend this period to three months, but we will notify you within one month if this is the case.

Where we process personal data based on consent, for example our Oxentia Newsletter, you have the right to withdraw your consent at any time by clicking on the unsubscribe link which we include in all our marketing emails.

As well as rights of access and amendment referred to above, you may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability.

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.

If you have any complaints concerning Oxentia’s processing of your personal data please email us at datacontoller@oxentia.com or write to us at Data Privacy Manager, Oxentia Ltd, Buxton Court, 3 West Way, Oxford, OX2 0JB, UK

This Privacy Statement will be kept under regular review and was last updated on May 21 2018.