IMPORTANT INFORMATION AND WHO WE ARE
Purpose of the Policy
The Policy aims to give you information on how Oberon collects and processes your personal data through your use of this website, including any data you may provide through this website when you-purchase a service
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this policy together with any other data protection guidance 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 Policy supplements other notices and privacy policies and is not intended to override them.
Oberon Investments Group plc is made up of several legal entities, Oberon Investments Limited, Smythe House Limited and Logic Investments Limited. This Policy is issued on behalf of the Oberon Group so when we mention “COMPANY”, “we”, “us” or “our”, we are referring to the relevant company in the Oberon Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Oberon Investments Group plc is the controller responsible for this website.
Full name: Galin Ganchev
Email address: firstname.lastname@example.org
Postal address: Oberon Investments Group, 2nd floor Nightingale House, 65 Curzon Street, London, W1J 8PE
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, and so invite you contact us in the first instance.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THE DATA WE COLLECT ABOUT YOU
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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- 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.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Oberon may, where necessary, collect some of your Special Category Data. This is to fulfil our regulatory obligations and so that we can best support you as a client. Where Special Category Data is collected, it will only be done with your explicit consent. Special Category Data includes your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health.
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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our services;
- subscribe to our service or publications;
- request marketing to be sent to you; or
- give us feedback or contact us.
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 the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact 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 UK.
- Identity, Financial and Contact Data, from Independent Financial Advisers.
HOW WE USE YOUR PERSONAL DATA
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.
- Where we need to comply with a legal obligation.
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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 contacting us.
Purposes for which we will use your personal data
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.
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.
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To register you as a new customer
|Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)
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 Identity, Contact, Technical, Usage and Profile 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 services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time at email@example.com or by writing to us at our contact address.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, service experience or other transactions.
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.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Companies within the Group as set out in the Glossary.
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.
Our primary storage and backup database are situated in the UK. Nevertheless, the data and personal information we gather and process may be moved to and stored in a location outside the UK. This transfer often occurs through a third-party system, especially when utilizing a cloud-based platform. We guarantee the implementation of suitable safeguards to ensure that your information and personal data are protected in a manner consistent with their management and storage within the UK.
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 legitimate reason to access it. They will only process your personal data in line with our instructions and they are subject to a duty of confidentiality.
Oberon has 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.
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.
Details of retention periods for different aspects of your personal data are available in our Retention Policy which is available on request.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years after they cease being customers for the purpose of complying with FCA regulations and rules.
In some circumstances you can ask us to delete your data; see the Glossary for further information.
There will be times where 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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please refer to the Glossary to find out more about these rights.
- Right to be informed
- Right of access
- Right to rectification
- Right to erasure
- Right to restrict processing
- Right to data portability
- Right to object
- Right to withdraw consent
- Rights related to automated decision making including profiling
If you have any questions about this Policy, the way in which Oberon handles your personal information or wish to exercise any of the rights outlined above, please get in touch with us either at firstname.lastname@example.org with the subject heading “Privacy Concerns” or by writing to the DPO. We aim to respond to you within 30 days.
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 could 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 30 days. Occasionally, it could take us longer than that if your request is particularly complex, or if you have made a number of requests. In this case, we will notify you and keep you updated.
If you wish to raise a complaint on how we have handled your information or to exercise your rights, you can contact us either at email@example.com or by writing to the DPO at Oberon Investments Group, 2nd floor Nightingale House, 65 Curzon Street, London, W1J 8PE.
We hope that we can address any concerns you may have, but you can contact the Information Commissioner’s Office (ICO) for further information or to lodge your complaint by visiting their page at https://ico.org.uk/global/contact-us/.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal and regulatory obligation that we are subject to.
Internal Third Parties – Other companies in the Oberon Group acting as joint controllers or processors and who are based in the United Kingdom and provide services.
- Oberon Investments Limited
- Smythe House Limited
- Logic Investments Limited
External Third Parties – Third-party ID verification and Know Your Customer (KYC) screening providers such as SmartSearch acting as processors.
Professional advisers acting as processors including lawyers, IFAs, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators such as the Financial Conduct Authority and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Your Legal Rights
You have the right to
Be informed about the collection and use of your personal data.
- You must be provided with information regarding the purposes for processing your personal data, retention periods for that personal data, and who it will be shared with. This information should be provided at the time your personal data is collected.
- If at any point, personal data is obtained from other sources, you must be provided with privacy information within a reasonable period of obtaining the data and no later than one month.
Request access to and receive a copy of your personal data and other supplementary information (commonly known as a ‘subject access request’ or ‘SAR’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- You can make SARs verbally or in writing, including via social media.
- A third party can also make a SAR on behalf of another person.
- You should receive a response within one month of your request, although this time frame may be extended by two months if the request is complex or if we receive a number of requests from you.
- Information should be provided in an accessible, concise and intelligible format and disclosed securely.
- Access can only be refused if an exemption or restriction applies, or if the request is manifestly unfounded or excessive.
Request rectification 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 through supplementary information.
- You can make a request for rectification verbally or in writing.
- Requests for rectification must be responded to within one calendar month to respond to a request.
- In certain circumstances we can refuse a request for rectification and we may ask you to provide evidence to support your request.
Request erasure of your personal data (also known as ‘the right to be forgotten’). This enables you to ask us to delete or remove personal data held at the time the request is received. It does not apply to data that may be created in the future.
- You can make your request verbally or in writing.
- Requests for erasure must be responded to within one month, however, we may not always be able to comply with your request of erasure for specific legal reasons which you will be notified of.
The right to erasure applies if:
- the personal data is no longer necessary for the purpose which it was originally collected or processed it for;
- consent is the lawful basis for holding the data, and you withdraw your consent;
- legitimate interests is the basis for processing, you object to the processing of your data, and there is no overriding legitimate interest to continue this processing;
- the personal data is being processed for direct marketing purposes and you object to that processing;
- the personal data has been processed unlawfully;
- erasing the data is to comply with a legal obligation; or
- the personal data has been processed to offer information society services to a child.
Restrict or suppress the processing of your personal data where you have a particular reason for wanting the restriction. This may be because you have issues with the content of the information held or how the data has been processed.
- Restrictions are unlikely to be indefinite, but will need to be in place for a certain period of time, depending on the reason for the request.
- This is not an absolute right and only applies in certain circumstances.
- You can make a request for restriction verbally or in writing and the request should be responded to within one calendar month.
You have the right to request you restrict the processing of their personal data in the following circumstances:
- you contest the accuracy of the personal data held and you wish to verify the accuracy of the data;
- the data has been unlawfully processed, you oppose erasure and would prefer to request restriction instead;
- the personal data is no longer needed but you need it to be kept in order to establish, exercise or defend a legal claim; or
- you object to the processing of your data and the processor is considering whether their legitimate grounds override yours.
Data portability. You have the right to obtain and reuse your personal data for your own purposes across different services.
- This right allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability.
- The right only applies to information you have provided to a controller.
The right only applies when:
- the lawful basis for processing the information is consent or for the performance of a contract; and
- the processing is carried out by automated means.
Object to the processing of your personal data in certain circumstances.
- You have an absolute right to stop your data being used for direct marketing.
- In other cases where the right to object applies, processing may continue if it can be shown that there is a compelling reason for doing so.
- You can make an objection verbally or in writing and this must be responded to within one calendar month.
Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw 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 communicate withdrawal.
Rights related to automated decision making including profiling
The UK GDPR also has provisions on:
- automated individual decision-making (making a decision solely by automated means without any human involvement); and
- profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.
Oberon cannot make solely automated decisions, including those based on profiling, that have a legal or similarly significant effect on individuals unless an exception applies.
We can only carry out solely automated decision-making with legal or similarly significant effects if the decision is:
- necessary for entering into or performance of a contract between an organisation and the individual;
- authorised by law (for example, for the purposes of fraud or tax evasion); or
- based on the individual’s explicit consent.
When using special category personal data, Oberon can only carry out processing if:
- we have the individual’s explicit consent; or
- the processing is necessary for reasons of substantial public interest.
More information about your legal rights can be found on the ICO website here: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/individual-rights/
REVIEW OF THE POLICY
This Policy will be officially monitored for compliance by Oberon on an annual basis or more often as required. It was last updated in December 2023.