Privacy Policy

THINGS TO KNOW ABOUT HOW WE TREAT OUR CUSTOMERS' PERSONAL DATA WHEN USING OTCTOOLBOX.COM

INTRODUCTION

Hello. We are Source Publishing Limited, trading as OTCToolbox. For the purpose of data protection laws, we are the 'controller' of the personal information collected in connection with the use of OTCToolbox.com. For more details about us, please see the Contact Us section below.

In this Privacy Policy, we explain what personal information we collect and how we may use it. This notice also explains how we comply with the law on data protection and what your rights are.

This notice applies to you if:

  • you are an employee or other individual accessing this site on behalf of your company that has purchased a subscription, a publication or a ticket to a conference from OTCToolbox.com; or
  • you have signed up via OTCToolbox.com to receive free news alerts from us; or
  • we have responded to a query you have made via OTCToolbox.com

This notice does not form part of any contract for purchase of any of our publications, subscriptions or conference tickets. If you want to understand on what basis you buy any of those, please see our Terms & Conditions.

Date posted: 1st August 2019

 

WHO DO I CONTACT WITH QUERIES ABOUT MY PERSONAL DATA?

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our Data Protection Compliance Manager has overall responsibility for data protection compliance at OTCToolbox.com. To contact them, please email data@otctoolbox.com.

WHAT PERSONAL INFORMATION DO YOU COLLECT?

When you interact with us or we interact with you in relation to our products and services, you may provide us with or we may obtain personal information about you, such as the following:

  • Contact details: information that allows us to contact you directly such as your name, job title, business email address, business telephone number and business addresses.
  • Transaction details: details of the items you have asked us to provide to you and other instructions and decisions made by you in relation to our products or services;
  • Financial information: details of transactions with you, though we do not see any card details (as this is dealt with by our payment provider, SagePay);
  • Records of your interactions with us: such as any enquiries or complaints you make, telephone conversations, letters and other correspondence (including e-mail) and your usage of our website.
  • Online account information: use of and movements through our online portal, passwords, personal identification numbers, IP addresses, user names and other IT system identifying information;
  • Responses to any feedback forms or surveys: we keep records of any responses you give us;
  • Your marketing preferences: so that we know whether and how we should contact you.

WHERE DO WE COLLECT YOUR PERSONAL INFORMATION FROM?

We will collect your personal information from a number of sources. These include the following:

  • Directly from you: when you use our site or contact us by phone, email or communicate with us directly in some other way (e.g. when we meet you at conferences and events);
  • From your company: your company may provide information to us, such as your name so that, for example, we can set you up as part of their subscription to our publications, or to buy a ticket for you to attend a conference;
  • Our site: provides us with information about how you use it and the devices that you use to connect to our site;
  • Providers of information: which may include credit reference agencies, Companies House, LinkedIn and other web platforms; and
  • Sub-contractors: such as our couriers, import/export agents, shippers, service sub-contractors, payment processors and any other sub-contractors.

If you are providing information regarding other individuals to us they have a right to know and to be aware of what personal information we hold about them, how we collect it and how we use and may share that information. Please share this Privacy Policy with them. They also have the same rights as set out in What rights do you have? below .

WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?
The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.

PURPOSE PERSONAL INFORMATION USED LAWFUL BASIS

To enable us to provide our publications, subscription and tickets to conferences to the organisation you work for

All the personal information we collect

 

This is necessary to fulfil our contract with the organisation you work for

We have a legitimate interest to fulfil our contracts with third parties

Make payments to and receive payments from the organisation you work for Transaction details and financial information

This is necessary to fulfil our contract with you

We have a legitimate interest to fulfil our contracts with third parties

Marketing our services or products which may be of potential interest to the organisation you work for Name, personal contact details and other identifiers, and marketing preferences

We have a legitimate interest in marketing our services to you and the organisation you work for in order to make new sales

You may have requested that we send to you details of certain products and/or services

We also may have obtained your explicit consent

To manage our relationship with you and any organisation you work for and operate and manage our business and internal reporting  All the personal information we collect about you

We have a legitimate interest to ensure that we operate efficiently and manage our business properly

To be able to manage and perform our contract with you

We have a legitimate interest to fulfil our contracts with third parties

To deal with enquiries, complaints and other communications from you or the organisation you work for and dealing with legal disputes involving you or the organisation you work for  All the personal information we collect about you

We have a legitimate interest to ensure that we operate efficiently and deal with any enquiries, complaints or other communications

We have a legitimate interest to ensure that all legal claims are managed effectively

For the purposes of staff training All the personal information we collect We have a legitimate interest to improve the services or products we provide
To perform credit checks Contact details and payment information We have a legitimate interest in ensuring we are likely to be paid for our products or services

To provide you with site access and for the purposes of ensuring the security of our systems and our information including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution

Online account information and your usage of our site and any IT services or functions we make available to you

We have a legitimate business in ensuring our systems are secure

To be able to manage and perform our contract with you

We have a legitimate interest to fulfil our contracts with third parties

To conduct data analytics studies and customer satisfaction surveys to review, and better understand our customer, retention, attrition and satisfaction levels Our client records and any information you provide in response to our client satisfaction surveys We have a legitimate interest in order to improve as a business
For the purpose of complying with any legal and regulatory requirements  All the personal information we collect about you We have a legal obligation to comply with any legal requirements
Storage of records relating to you and also records relating to our business All the personal information we collect about you To be able to manage and fulfil our contract with the organisation you work for, we may have a legal and/or regulatory obligation to do so and we also have a legitimate interest to keep proper records


For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to properly perform our contract with the organisation you work for or comply with legal obligations.

You should be aware that it is not a condition of any contract with us that you agree to any request for consent from us and we do not usually rely on consent as a basis for processing your personal information. However if we have asked you for consent, and you have given us your consent to use your personal information, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the Contact us section below.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide carry out certain activities.

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

We share personal information with the following parties:

  • Other service providers to our business and advisors: third party banks, administration and IT services and other service providers. All our third-party service providers are required to take appropriate security measures to protect your personal information.
  • The organisation you work for.
  • Purchasers of our business: buyers or perspective buyers to whom we may sell or negotiate to sell our business.
  • Sub-contractors: such as our payment processors, MailChimp and other sub-contractors.
  • The Government, government bodies or our regulators: where we are required to do so by law or to assist with their investigations or initiatives, for example HMRC or the Information Commissioner’s Office.
  • Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell, rent or trade your data.

DIRECT MARKETING

Email, post and telephone: from time to time, we may contact you by email, post and/or telephone with information about products or services we believe you may be interested in.

We will only send marketing messages to you in accordance with the marketing preferences you set when you create your account or that you tell us afterwards you are happy to receive or where you or the organisation you represent have purchased similar services or goods from us previously or you ask us to send you the information.

You can then let us know at any time that you do not wish to receive marketing messages by sending an email to us at data@otctoolbox.com or by using the by using the details set out in the Contact Us section below. You can also unsubscribe from our marketing by clicking on the unsubscribe link in any written marketing messages we send to you or by letting us know during any marketing telephone call from us.

TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Union except as set out in this section.

Our staff and other individuals working for us may in limited circumstances access personal information outside of the UK and European Union if they are on holiday or working abroad outside of the UK or European Union. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK.

In limited circumstances the people to whom we may disclose personal information as mentioned in Who do we share your personal information with above may be located outside of the UK and European Union. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.

If you require more details on the arrangements for any of the above then please contact us using the details in Contact Us below.

HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement, we retain all physical and electronic records for a period of approximately 6 years following the end of our customer relationship with you or the organisation you work for because this is the limitation period for claims related to breach of contract. The exceptions to this general rule are:

  • Where the organisation you work for has not yet become a customer and we are only engaged in marketing to you, we will retain your details for a period of 4 years since our last interaction, unless the organisation you work for later becomes a customer; and
  • Where you have asked not to be sent marketing messages, we keep your information so that we know not to send you marketing messages. We keep this information indefinitely.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address. You may be able to update some of the personal information we hold about you through your account on our site. Alternatively, you can contact us by using the details set out in the Contact us section below.

YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION

You have the following rights in relation to your personal information:

  •  the right to be informed about how your personal information is being used;
  • the right to access the personal information we hold about you;
  • the right to request the correction of inaccurate personal information we hold about you;
  • the right to request the erasure of your personal information in certain limited circumstances;
  • the right to restrict processing of your personal information where certain requirements are met;
  • the right to object to the processing of your personal information;
  • the right to request that we transfer elements of your data either to you or another service provider; and
  • the right to object to certain automated decision making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example we do not use automated decision making in relation to your personal data. However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

Although this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the Contact us section below.
If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office. We are here to help and encourage you to contact us to resolve your complaint first.

CHANGES TO THIS NOTICE

We may update this Privacy Notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of the front page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

CONTACT US
In the event of any query or complaint in connection with the information we hold about you, please email data@otctoolbox.com or write to us at Source Publishing Limited, 54 Creynolds Lane, Cheswick Green, Solihull, West Midlands, B90 4ER, United Kingdom.