PRIVACY POLICY

This privacy notice provides information on how OGE Solutions Ltd collects and processes your personal data when you visit our website.
This website is not intended for children and we do not knowingly collect data relating to children.

1. IMPORTANT INFORMATION AND WHO WE ARE

OGE Solutions Ltd is the controller and responsible for your personal data (referred to as ‘Company’, ‘we’, ‘us’ or ‘our’ in this privacy policy). We have a data protection officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

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Contact Details
Our full details are:
· Full name of legal entity: OGE Solutions Ltd (company number: 10163354);
· Name and title of DPO: Matthew Cox, Director;
· Email address: procurement@ogesolutions.co.uk;
· Postal address: 24/25 The shard, 32 London Bridge Street, London, SE1 9SG; and
· Telephone number: 020 3633 1149

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Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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2. THE DATA WE COLLECT ABOUT YOU

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We may collect, use, store and transfer different kinds of personal data about you as follows:

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· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
· Contact Data includes email address and telephone numbers;
· Technical Data includes 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 Data includes information about how you use our website, products and services; and
· Marketing and Communications Data includes your preferences in receiving marketing materials from us and our third parties and your communication preferences.

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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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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We will collect this personal data from you by direct interactions, for example when you fill in forms or correspond with us, or automatically, for example when we use cookies to collect technical data about your use of our website. Please see our Cookie Policy for further details.

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3. HOW WE USE YOUR PERSONAL DATA

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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:

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· 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; or
· Where we need to comply with a legal obligation.

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We will only use your personal data for the purpose for which we collected it which include the following:

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· To register you as a new customer/user;
· To manage your relationship with us;
· To enable you to participate in a prize draw, competition or complete a survey;
· To improve our website, products/services, marketing or customer relationships; or
· To recommend products or services which may be of interest to you.

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Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

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Promotional Offers from Us

We may use your 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 products, 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 goods or services from us and you have not opted out of receiving that marketing.

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Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

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Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or 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 product or service purchase, experience or other transactions.

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Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy

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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.

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4. HOW WE SHARE YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes above, and:

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· Third parties we use to help deliver our products and services to you, e.g. payment service providers, and website hosts; and
· 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 policy.

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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.

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5. INTERNATIONAL TRANSFERS

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

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Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

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· We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
· Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

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6. 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.
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.

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7. DATA RETENTION

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How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.
In some circumstances we will 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.

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8. YOUR LEGAL RIGHTS

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Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are as follows:

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· Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check 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:
o if you want us to establish the data’s accuracy;
o where our use of the data is unlawful but you do not want us to erase it;
o 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; and/or
o 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 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.

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No fees usually required

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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, in our reasonable opinion, your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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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 for further information in relation to your request to speed up our response.

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Time limit to respond

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We try to respond to all legitimate requests within one month. Occasionally it could 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 of our progress.