Introduction
Oona Health (collectively referred to as “Oona”, “we”, “us” or “our” in this privacy notice) respects your privacy and is committed to protecting your personal data. This privacy notice explains the information we process about you as a data controller in the following circumstances:
When you enquire about our products and services;
When we communicate with you in order to provide our products and services to you as a Oona Health customer;
When you use our corporate website;
When we conduct marketing activities.
This privacy notice is provided in a sectioned format so you can find the specific information you want under the relevant topic areas. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
Oona's services and corporate website are 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.
1. Who we are and how to contact us
Oona Health is a company registered with the European Union Intellectual Property Office under company number 018580626. You can contact us if you have questions about this Privacy Policy of about your personal data in general.
You have the right to make a complaint to us at any time if you think we have breached your data protection rights. If you are not satisfied with our response, you are also able to make a complaint to the Information Commissioner’s Office (ICO). Please go to www.ico.org.uk.
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, when you interact with us, which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier.
Contact Data includes email address.
Technical Data includes internet protocol (IP) address, 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 the corporate website.
Profile Data includes information about your preferences in relation to our products and services which we obtain though our interactions with you.
Usage Data includes information about how you use the corporate website and its contents.
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.
3. How is your personal data collected?
We use different methods to collect data from and about you on our corporate website through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by email, phone or otherwise.
This includes personal data you provide when:
You enquire about our products and services i.e. via the “Contact Us” page on our corporate website;
You enter into a contract with us for the provision of our products and services;
You contact us to get help or give us some feedback.
You take part in surveys that we think are relevant to you and to provide outputs on opinion polls or surveys you’ve participated in.
Automated technologies or interactions. As you interact with our corporate website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Technical Data from analytics providers such as Google based outside the EU.
4. 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 duties 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 or regulatory obligation. Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to opt out from marketing at any time by clicking the unsubscribe link in any email you receive from us or by contacting us.
Please refer to the “Lawful Basis” section of the Glossary in this privacy notice, to find out more about the types of lawful basis that we will rely on to process your personal data.
5. Purposes for which we will use your personal data
We have set out below, a description of all the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what Oona’s 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.
To respond to your queries made via the Contact Us page on our corporate website or any other means. We may keep a record of your queries to inform any future communication with us and to demonstrate how we communicated with you throughout.
Necessary for our legitimate interests.
To manage our relationship with you as a Oona customer or supplier.
Necessary for our legitimate interests.
To notify you about changes to our terms or privacy policy.
Necessary to comply with a legal obligation.
To administer and protect the technical systems on which our corporate website operates (including troubleshooting, data analysis, testing, system maintenance, support).
Necessary for our legitimate interests, Necessary to comply with a legal obligation.
To use data analytics to improve our corporate website user experience.
Necessary for our legitimate interests (to keep our corporate website updated and relevant and to develop our business).
To invite you to take part in surveys that we think are relevant to you and to provide outputs on opinion polls or surveys you’ve participated in. We will use your personal data to provide the output and keep you informed by email of changes and invite you to update your opinions / views previously provided.
Necessary for our legitimate interests
To market our services. We will use your personal data, preferences and details of your transactions to keep you informed by email, web, telephone about relevant content, products and services including, but not limited to, information, tailored offers, discounts, promotions, events and competitions. Our marketing will follow best practice laid out by the Information Commissioner’s Office (ICO) when dealing with corporate subscribers under the PECR.
Necessary for our legitimate interests.
Change of Purpose
We commit to only process your personal information for the purposes outlined above. If these purposes change over time or we want to use data for a new purpose which we did not originally anticipate, we will only go ahead if the new purpose is compatible with the original purpose. If the new purpose is incompatible with the original purpose, we will seek your specific consent for the new purpose; or if a clear legal provision exists requiring or allowing the new processing in the public interest, we will inform you accordingly.
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 section 6 above:
External Third Parties, as set out in the Glossary of this privacy notice.
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 are based in the UK but sometimes your personal information may be transferred outside of the European Economic Area (EEA). For example, some of our third party suppliers to which we disclose your personal data may be situated outside of the EEA. Where we do transfer your personal data outside of the EEA, we make sure that we put one of the EU’s approved suitable safeguards in place, for example using approved contractual agreements or by obtaining your explicit consent for the transfer.
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 your employer or our instructions (as applicable) 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 we use your personal data for?
We retain your personal information for the minimum reasonable time period to allow us to fulfil the purposes that we collected it for. We will delete or destroy your data after that time except where we need to keep any personal information to comply with our legal obligations, resolve ongoing disputes or defend ourselves against future legal claims, or enforce our agreements.
Occasionally, we may continue to use data without further notice to you. This will only be the case where any such data is anonymised and you cannot be identified as being associated with that data.
Please contact our DPO for further information about our retention periods.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please refer to the “Your Legal Rights” section in the Glossary.
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 reserve the right to 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 one month. Occasionally it may 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.
11. Glossary
LAWFUL BASIS
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).
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.
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.
EXTERNAL THIRD PARTIES
Service providers acting as processors for Oona, who provide IT, IT security and system support and administration services.
YOUR LEGAL RIGHTS
You have the right to:
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. 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: (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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
12. Changes to the privacy notice
This version was last updated on 17.03.2022
As Oona Health changes, this Privacy Policy is expected to change as well. We reserve the right to amend this Privacy Policy at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy on our corporate website. We may email periodic reminders of this Privacy Policy and will email relevant data subjects to notify them of any material changes. You should check our corporate website frequently to see the current Privacy Policy that is in effect and any changes that may have been made to it.