This website is operated by Openwage Limited. We are a company incorporated in England and Wales under company registration no: 12957705 with a registered address at: Leconfield House, Curzon Street, London, England, W1J 5JA.
We collect, use and are responsible for certain personal information about you. When we do so we are compliant with the provisions of the Data Protection Act 2018 and we are responsible as ‘controller’ of that personal information for the purposes of that legislation.
Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.
We collect personal information about you when you access our website, register with us to use the service, contact us, or send us feedback via our website.
We collect this personal information from you either directly, such as when you register with us or access our services via our website or indirectly, such as your browsing activity while on our website (see ‘Cookies’ below).
The personal information we may collect about you depends on the particular activities carried out through our website.
This information may include:
We may also collect behavioural data relating to your website visits and app usage, such as Internet Protocol (IP) address, mobile device identifier, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, download errors, response time, page interaction (such as scrolling, clicks, and mouse-overs) device type and model, operating system and platform and other technology on the devices you use to access the services we provide.
Lastly, we may collect technical data: this may include data that is inferred or assumed information relating to your behaviour and interests, based on your activity online and/or in the application. This data will be anonymised and aggregated but may be collated and grouped into “segments” (e.g., there may be a segment for users, living in London and aged under 25, who use our services twice a month).
We use this personal information to:
This website is not intended for use by children and we do not knowingly collect or use personal information relating to children.
When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.
The legal bases we may rely on include:
For further details on when we collect personal information, what we collect as well as how we use it, please read the following sections.
We have set out below, in a table format how we use your Personal Data.
|PURPOSE||CATEGORIES OF PERSONAL DATA||WHY WE DO THIS||OUR LEGAL BASIS FOR THIS USE OF DATA|
|Account creation||Identity data|
|To register you as a new user||Legitimate Interest|
|Transfers and Service Provision||Identity data|
|To provide you with the Openwage services and communications on behalf of your employer||Performance of Contract|
|Making third party product available||Identity data|
|To enable you to access third party products||Consent|
|Fraud Prevention||Identity data|
|To keep our website, our services and associated systems operational and secure and to keep your data and identity secure||Performance of Contract|
|Troubleshooting||Technical data||To track issues that might be occurring on our systems||Performance of Contract|
|Optimisation and Analytics||Identity data|
|To understand and measure how users use our platform to improve it and report and relevant aggregated management information||Performance of ContractLegitimate Interest|
|To capture interest in Openwage and to keep prospects and clients informed||Consent|
|Product Referrals||Identity data|
|To allow interested employees to refer Openwage to their employer||Legitimate Interest|
|Survey Invitation||Identity data|
|Improve our service||Legitimate Interest|
We may share your personal data with the parties set out below for the purposes set out in the table at section 4 above “Purposes for which we will use your personal data”.
We require all third party service providers to respect the security of your personal data and to process it in accordance with data protection 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.
|RECIPIENTS||CATEGORIES OF PERSONAL DATA SHARED||REASON SHARED|
|Service Providers||Identity Data|
|So that survey, hosting, analytics, search engine and other technical assistance providers can assist us in the improvement and optimisation of the Openwage website.Survey companies are only permitted to use your personal data to request a review from you in the context of your use of the Openwage website. They may not use it for any other purpose.Our IT service providers provide us with software development, business analyst and system administration services.|
|Communication Partners||Contact Data||Our third-party partners provide live chat and facilitate communication (like email, chat and phone), in order to provide you with the full functionality of the Openwage website.They may ask for your name and email to provide assistance to you.|
|Professional advisers||Identity Data|
|To our lawyers, bankers, consultants, auditors and providers of banking, legal, insurance and accountancy services if such disclosure is reasonably required to comply with any legal obligation; to enforce any contract entered into with you; to protect the rights, property or safety of Openwage or our customers (including by exchanging information with other organisations for the purposes of fraud protection).|
|Openwage Group Companies||Identity Data|
|We may share your information with our corporate affiliates and associates (e.g., parent company, sister companies, associated trust entities, subsidiaries, joint ventures, or other companies under common control). We have a legitimate business interest to share data with our group as it allows us to better understand the performance of our services and how to offer and improve our product offerings across the group. It also assists us with finding operational efficiencies (such as financial efficiencies though sharing IT infrastructure), making use of group level software solutions and improving our technological offerings which form an integral part of our Service.|
|Purchaser of Openwage and/or any member of the Openwage Group||Identity Data|
|Law Enforcement Agencies||Identity Data|
|On the basis of the compliance with a legal obligation for example if we are required to disclose information pursuant to regulatory, employment, taxation, criminal, terrorist financing and money laundering law requirements.|
|Legal, civil or business affairs||Identity Data|
|We may disclose information when we believe disclosure is appropriate to comply with the law, to enforce or apply applicable terms and conditions and other agreements, or to protect our rights, property or safety or the rights, property or safety of our affiliates, users, or third parties. For example, we may disclose information in response to subpoenas, arbitration proceedings, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.|
We will share personal information with law enforcement or other authorities if required by applicable law.
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
Digital Marketing Service Providers – We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.
Our appointed data processors include:
We will not share your personal information with any other third party.
We may use and share personal data that is aggregated and anonymised (“Aggregated Data”) for statistical purposes only. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we will treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.
We require you to provide your name or your employer’s name, email address and/or phone number to enable us to contact you and/or your employer. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
We will not transfer your personal information outside the United Kingdom (UK) and/or the European Economic Area (EEA).
For further information on cookies, when we will request your consent before placing them and how to disable them, please see our https://openwage.com/cookie-policy/
We would like to send you information about special offers, newsletters our products and services, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.
If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:
—contacting us at firstname.lastname@example.org
—using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
—updating your marketing preferences on our preference centre
It may take up to 5 days for this to take place.
For more information on your rights in relation to marketing, see ‘Your rights’ below.
Under the Data Protection Act 2018 you have a number of important rights free of charge. In summary, those include rights to:
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under Data Protection legislation.
If you would like to exercise any of those rights, please:
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We hope that we can resolve any query or concern you raise about our use of your information.
The Data Protection legislation also gives you the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state or in the United Kingdom if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us, please send an email to email@example.com, write to Openwage, Leconfield House, Curzon Street, London, England, W1J 5JA.