.360 OM Limited are committed to providing You with notice as required by law if we make material changes to this Privacy Statement, Your continued use of the Website or our services will signify acceptance of the terms of the updated Privacy Statement.
1. The Information We Collect.
360 OM collects information from users of our Website, potential clients and
clients of our services, suppliers and vendors (actual and potential), applicants for employment and participants in events that we may organize or promote. Depending on the nature of the services provided by 360 OM, we may receive information from You (a Website visitor, potential client, or client) directly, or from our clients, who may send us Your information in order to fulfill a service to You on their behalf. The information may include Your name, mailing address, email address, phone number, credit card information and other data required to provide You with the product or service You requested.
We may automatically collect certain information about the computer or devices (including mobile devices or tablets) You use to access the Website or services. As described further below, we may collect and analyze information such as (a) IP addresses, location information, unique device identifiers, IMEI and TCP/IP address, and other information about Your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which You accessed the Website or services; and (b) information related to the ways in which You interact with the Website or services, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Website or services, the amount of time spent on particular pages, the date and time You used the Website or services, the frequency of Your use of the Website or services, error logs, and other similar information.
As described further below, we may use third-party analytics providers and technologies, including “Cookies”, as defined below, and similar tools, to assist in collecting this information.
Whether for our own purposes or those of our clients, we may also collect data about Your use of our Website, our ads, or ads and sites we track on behalf of our clients, through the use of Internet server logs (where we store Website activity) and cookies and/or tracking pixels. We may be provided information relating to visitors to the Website by third-parties that use tracking technology to identify such visitors based on their IP addresses.
- Lead Forensics: https://www.leadforensics.com/privacy-and-cookies/
- Google Analytics: https://www.google.com/analytics/terms/us.html
- Hotjar: https://www.hotjar.com/legal/policies/privacy
- Facebook: https://www.facebook.com/policy/cookies/
If You wish to opt out of interest-based advertising, by opting out of many of the online advertising and data platforms that provide this advertising, You may go to the DAA opt-out portal at http://aboutads.info, or the NAI opt-out portal at http://www.networkadvertising.org.
Some Cookies are placed in Your browser cache while those associated with Flash technologies are stored with Your Adobe Flash Player files. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in Websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and to access user Cookies. We also may include web beacons in email messages, newsletters and other electronic communications to determine whether the message has been opened and for other analytics, personalization and advertising. As we adopt additional technologies, we may also gather additional information through other methods.
Please note that You can change Your settings to notify You when a Cookie is being set or updated, or to block Cookies altogether. Please consult the “Help” section of Your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including Cookies and local storage objects with the Flash management tools available at Adobe’s Website. Please note that by blocking any or all Cookies, You may not have access to certain features or offerings of the Services.
2. How We Use the Information We Collect.
360 OM uses the data we collect as follows:
For the purposes for which You provided it;
- To recognise and authenticate You on the services;
- To initiate or to provide the features, services and products available
through the Website or our services;
- To send You information about Your relationship or transactions with us, account alerts, or other communications, such as newsletters to which You have subscribed;
- To contact You with information or surveys that we believe may be of interest to You both regarding our products and services and those of third parties;
- To process and respond to Your inquiries or to request Your feedback;
- For internal research and reporting;
- To improve the content and features of the Website or our services or
develop new services;
- To enforce the legal terms that govern Your use of the Website or our
- To administer and troubleshoot the Website or our services.
- To send You communications required by law or which are necessary to
Please note that we may combine information that we collect from You and about You (including automatically-collected information) with information we obtain about You from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Privacy Statement.
We may aggregate and/or de-identify information collected through the Website or services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and/or others.
3. How We Disclose Your Information.
360 OM will disclose Your information as follows:
- To third parties who perform services on our behalf, including without limitation marketing, market research, customer support, data storage, analysis and processing, and legal services. (Specifically, 360 OM uses, Office365 (a business of Microsoft) to manage email correspondence with clients, prospective clients and other business contacts. We may use other similar services in future.);
- To manage its relationships, correspondence and record-keeping in respect of clients and prospective clients. (360 OM currently uses Hubspot, among other companies such Asana, to support this activity.)
- To process financial records. (360 OM uses Intuit Inc, among other companies, to support this activity.)
- To suppliers employed by our clients who will then fulfill the product or service requested to You directly.
- Where required to do so by law or in a good faith belief that such access, preservation, or disclosure is permitted by this Privacy Statement or reasonably necessary or appropriate for any of the following reasons: (a) to comply with legal process; (b) to enforce this Privacy Statement or other contracts with You, including investigation of potential violations thereof; (c) to respond to claims that any content violates the rights of third parties; (d) to respond to Your requests for customer service; and/or (e) to protect the rights, property, or personal safety of 360 OM, its agents and affiliates, its users, and the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
- As part of business transactions, (including in contemplation of such transactions, e.g., due diligence), such as buying, merging with, or partnering with other businesses or as part of an asset sale.
4. Requests for Personal Information by Law Enforcement or Government Agencies.
360 OM may be required to respond to court orders or be asked to respond to legitimate requests for Your personal information from law enforcement or government agencies. In such situations, we will release Your information to these organizations as we reasonably believe appropriate for us to comply with the law and to prevent against fraud. 360 OM will not provide You with these requests for information made by law enforcement or government agencies.
We have implemented administrative, technical, and physical security measures designed to protect against the loss, misuse, and/or alteration of Your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose Your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.
Whenever we collect or process Your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, we will either delete Your data completely or anonymise it, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
7. Data Transfers
Our computer systems are currently based in the United Kingdom and we may process and store Your information in one or both of these locations. As such, we may not provide the same level of protection as the privacy laws of Your jurisdiction. By providing us with Your information, You understand that Your personal information will be processed in the United Kingdom.
Additionally, we will ensure, through contractual clauses that Your data receives at least the same protection as if it were being processed inside the UK.
8. Your Choices and Rights
9. How to Contact Us
If You have any questions regarding our privacy practices in the United Kingdom, You may contact Tariq Mohammed, Esq. by mail at 360 OM,Toffee Factory, Newcastle Upon Tyne, NE1 2DF, by phone at +44330 808 6743 or by email on firstname.lastname@example.org.
10. General Data Protection Regulation
The EU General Data Protection Regulation (or the “GDPR”) requires 360 OM and those using our services to provide users with certain information about the processing of their “Personal Data.” “Personal Data” is a term used in Europe that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, Cookie identifiers, mobile device identifiers, precise location data and biometric data.
To comply with the GDPR, we provide the below representations and information, which are specific to persons located in EEA countries or Switzerland (so please don’t rely on the below, if You’re not):
a. Legal Grounds for Processing Your Personal Data
When we act as a “data controller”, the GDPR requires us to tell You about the legal basis we’re relying on to process any Personal Data about You. The legal basis for us processing Your Personal Data for the purposes set out in the “Types of Information We Collect and How We Use It” section above and will typically be because:
Legitimate Interests. In some cases, we use legitimate interest as a legal basis for processing Personal Data. We rely on legitimate interest when we use Personal Data to maintain the security of our services, and when we communicate with or otherwise manage our client data.
You provided Your consent.
Contractual Relationships. Sometimes, we process certain data as necessary under a contractual relationship we have (such as our client records and contact information);
Legal Obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.
b. Personal Data Retention
As a general matter, we retain Your Personal Data for as long as necessary to provide our Website and services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements, as well as for auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes.
c. Your Rights as a Data Subject
The GDPR provides You with certain rights in respect of Personal Data that data controllers hold about You, including certain rights to access Personal Data, to request correction of the Personal Data, to withdraw Your consent where we process Your Personal Data pursuant to Your consent, to request to restrict or delete Personal Data, and to object to our processing of Your Personal Data (including profiling for online ad targeting). To exercise those rights, You may contact us as described above, in Section 12.
However, where we process Personal Data on behalf of a client (which is often the case), we may refer the request to the relevant client and cooperate with their handling of the request, subject to any special contractual arrangement with that client. Many of the rights described here are subject to significant limitations and exceptions under applicable law. For example, objections to the processing of Personal Data, and withdrawals of consent, typically will not have retroactive effect. You also have the right to lodge a complaint with a supervisory authority. However, we hope that You will first consult with us, so that we may work with You to resolve any complaint or concern You might have.
If You reside in the EU, following is a more detailed overview of Your rights under GDPR, if it applies to You.
You have the right to request:
Access to the personal data we hold about You, free of charge in most cases. The correction of Your personal data when incorrect, out of date or incomplete. That we stop using Your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent-based processing of Your personal data after You withdraw that consent.
You can contact us to request to exercise these rights at any time by emailing email@example.com:
If we choose not to take action on Your request we will explain to You the reasons for our refusal.
Your right to withdraw consent
Whenever You have given us Your consent to use Your personal data, You have the right to change Your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing Your personal data on the basis of our legitimate interest, You can ask us to stop for reasons connected to Your individual situation.
We must then do so unless we believe we have a legitimate overriding reason to continue processing Your personal data.
You have the right to stop the use of Your personal data for direct marketing activity through all channels, or selected channels. We must always comply with Your request.
Checking Your identity
If You have authorised a third party to submit a request on Your behalf, we will ask them to prove they have Your permission to act.
Date: 1st September 2020