This privacy notice aims to give you information on how Ozuma collects and processes your personal data through your use of this App, including any data you may provide through this App when you purchase a product or service or sign in to use the App.
This App is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 privacy notice supplements the other notices and is not intended to override them.
Ozuma is part of a group of companies made up of different legal entities. This privacy notice is issued on behalf of the Amuzo Group so when we mention “Ozuma”, “Amuzo”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Amuzo Group responsible for processing your data. Ozuma Ltd is the controller and responsible for this App.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Full name of legal entity: Ozuma Ltd
Data privacy manager: Peter Phillips
Email address: firstname.lastname@example.org
Postal address: Parkway House, 26 Avenue Road, Bournemouth, England, BH2 5SL
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 5th April, 2018.
It is important that the personal data we hold about you is accurate and current. You must keep us informed if your personal data changes during your relationship with us.
This App may include links to 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 Apps and are not responsible for their privacy statements. When you leave our App, we encourage you to read the privacy notice of every App and website you visit.
2. 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 follows:
Identity Data includes: first name, initials, last name, username or similar identifier.
Contact Data includes: email address only.
Financial Data is not taken
Transaction Data is not taken
Technical Data includes your login data, time zone setting and location, operating system and platform and other technology on the devices you use to access this App.
Profile Data includes: your username and password.
Usage Data includes: Analytics functions within App that compiles data. This data is anonymous.
Marketing and Communications Data is not included in this App.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App 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 notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
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.
3. 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 Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
download our products or services;
create an account on our App;
subscribe to our service or publications; or
give us some feedback.
Automated technologies or interactions. As you interact with our App, we may automatically collect Technical Data. We collect this personal data by using cookies, server logs and other similar technologies.
Further information on cookies is available online at: www.aboutcookies.org
5. 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. 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).
Under a Performance of Contract. Performance of 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.
Where we need to comply with a legal or regulatory obligation.
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, which we do not do within this App.
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.
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.
|Purpose/Activity||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 manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(e) 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 administer and protect our business and this App (including troubleshooting, data analysis, testing, system maintenance, support, statistical 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 App content to you
(e) Marketing and
Necessary for our Legitimate Interests (to
study how customers use our
products/services, to develop them, to
grow our business)
To use data analytics to improve our App, Products/services, marketing, customer relationships
Necessary for our Legitimate Interests (to define types of customers for our products and services, to keep our App updated and relevant, to develop our business and to inform our marketing strategy)
You can ask us to not use your data for marketing purposes. Where you opt out, this will not apply to personal data provided to us as a result of a product/service purchase, product/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.
6. 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 Clause 4 above.
Internal Third Parties as set out below.
External Third Parties as set out below.
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.
7. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”. For further details, see European Commission: Binding corporate rules.
8. 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.
9. 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.
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six (6) years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request Erasure below for further information.
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.
10. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• 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 andto 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.
• 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.
• 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 to 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
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 thirty (30) calendar days of receiving the request. Occasionally it may take us longer, if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
We ask that where you request in writing via post you send the request via recorded delivery to ensure safe receipt.
11. THIRD PARTIES
INTERNAL THIRD PARTIES
Other companies in the Amuzo Group acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake reporting.
EXTERNAL THIRD PARTIES
Third party companies that commissioned Amuzo or Ozuma to develop the App and content and use the personal data and use of content for their internal purposes.
Service providers who provide the platform for the App and IT and system administration services.
Professional advisers acting as processors or joint controllers including solicitors, barristers, bankers, auditors and insurers based in the United Kingdom or EEA who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Legal and governmental agencies acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
12. ICO, DATA PROTECTION ACT 1998 and GDPR
We adhere to the following working principles:
a) access to your information for our third-party clients is restricted to our relevant trained staff only;
b) where any hard copies are created, the hard copies of your information and confidential documents are kept securely under lock and key.
We have registered with the ICO under the Data Protection Act 1998 and adhere to the following principles:
a) All our relevant employees have received training in how to handle your information. This includes ensuring they are aware of the importance of handling your information safely and securely and understanding the procedures in place to ensure this happens.
b) We will periodically evaluate our database and securely delete any contacts no longer engaged or any information no longer needed by us. If you choose to opt out, we will securely delete your information immediately.
c) We have measures in place to keep your information we hold safe and secure.
d) All personal information is stored in secure web server hosted sites to which access is only granted to key personnel. Where your information is downloaded to be updated, and as a backup to the cloud, it is only stored on personal drives, only accessible via individual log in.
Nothing herein contained shall give rise to a partnership or a contract of employment between you and us.
No waiver or affirmation of any breach of or non-compliance with any term hereof by the parties shall be deemed to be a waiver or affirmation of any preceding or succeeding breach of or non-compliance with the same or any other term.
17. THIRD PARTIES