Privacy Policy

1. Introduction 
2. How We use personal data 
3. Sharing your personal data with others 
4. International transfers of personal data 
5. Retaining and deleting personal data 
6. The rights of Data Subjects 
7. Cookies 
8. Our details 
9. Contacting Us concerning the contents of this Privacy Policy 10. Amendments to this Policy
10. Introduction 

1.1 We are committed to safeguarding the privacy and accuracy of the personal  data of Our website visitors, service users and email recipients. 

1.2 This policy applies where We are acting as a Data Controller with respect to  the personal data of Our website visitors, service users, email recipients and  personal data collected from public sources; in other words, where We determine the  purposes and means of the processing of that personal data. 

1.4 In this policy, “We”, “Us” and “Our” refer to Oxygen Consultancy Limited – trading as Oxygen Consultancy. For more information about Us, see Section 8. 

1.5 Reference to a Data Subject means a natural person whose personal data is  processed by a Data Controller or a Data Processor, in other words, You. 

2.How We use Your personal data 

2.1 In this Section 2 We have set out: 

1. The general categories of personal data that We may process;
2. in the case of personal data that We did not obtain directly, the source and specific categories of that data;
3. the purposes for which We may process personal data; and
4. the legal bases of the processing.

2.1.1 The General Categories Of Personal Data That We May Process 2.1.1.1 Usage Data 

 We may process data about Your use of Our website and services (“Usage Data“). The Usage Data may include Your IP address, geographical location,  browser type and version, operating system, referral source, length of visit, page  views and website navigation paths, as well as information about the timing,  frequency and pattern of Your service use. The source of the Usage Data is Google  Analytics as well as Our analytics tracking system. This Usage Data may be  processed for the purposes of analysing the use of the website and services. The  legal basis for this processing is Our legitimate interests, namely monitoring and  improving Our website and services, and tailoring any communication with You. 

2.1.1.2 Account Data 

 We may process Your Account Data (“Account Data“). The Account Data may  include Your name and email address. The source of the Account Data is You or  Your employer. The Account Data may be processed for the purposes of providing  Our services, ensuring the security of Our website and services, maintaining back ups of Our databases and communicating with You. The legal basis for this  processing is the performance of a contract between You and Us and/or taking  steps, at Your request, to enter into such a contract. 

2.1.1.3 Service Data 

 We may process Your personal data that are provided in the course of the use  of Our services (“Service Data“). The Service Data may include name, email  address and telephone number. The source of the Service Data is You or Your  employer. The Service Data may be processed for the purposes of providing Our  services and communicating with You. The legal basis for this processing is the  performance of a contract between You and Us and/or taking steps, at Your request,  to enter into such a contract.

2.1.1.4 Enquiry Data 

 We may process information contained in any enquiry You submit to Us  regarding goods and/or services (“Enquiry Data“). The Enquiry Data may be  processed for the purposes of Us offering, marketing and selling relevant goods  and/or services to You. The legal basis for this processing is consent which may be  withdrawn by You at any time by contacting Us. 

2.1.1.5 Notification Data 

 We may process information that You provide to Us for the purpose of  subscribing to Our email notifications and/or newsletters (“Notification Data“). The  Notification Data may be processed for the purposes of sending You the relevant  notifications and/or newsletters. The legal basis for this processing is consent which  may be withdrawn by You at any time by contacting Us. 

2.1.1.6 Correspondence Data 

 We may process information contained in or relating to any communication that  You send to Us (“Correspondence Data“). The Correspondence Data may include  Your name, email address and the communication content and metadata associated  with the communication. Our website will generate the metadata associated with  communications made using the website contact forms. The Correspondence Data  may be processed for the purposes of communicating with You and record-keeping.  The legal basis for this processing is Our legitimate interests, namely the proper  administration of Our website and business and communications with users. 

2.1.1.7 Public Data 

 We may process information found on public social networking profiles (“Public Data“). This data may include name and job title. Public Data may be processed for  the purposes of offering, marketing and selling relevant goods and/or services to  Your employer. The legal basis for this processing is Our legitimate interests, namely  proper administration of Our business.

2.1.1.8 Legal Claims Data 

 We may process any of Your personal data identified in this policy where  necessary for the establishment, exercise or defence of legal claims, whether in  court proceedings or in an administrative or out-of-court procedure. (“Legal Claims Data”) The legal basis for this processing is Our legitimate interests, namely the  protection and assertion of Our legal rights, Your legal rights and the legal rights of  others. 

2.1.1.9 Professional Use Data 

 We may process any of Your personal data identified in this policy where  necessary for the purposes of obtaining or maintaining insurance coverage,  managing risks, or obtaining professional advice. (“Professional Use Data”). The  legal basis for processing Legal Claims Data is Our legitimate interests, namely the  proper protection of Our business against risks. 

2.2 In addition to the specific purposes for which We may process Your personal  data set out in this Section 2, We may also process any of Your personal data where  such processing is necessary for compliance with a legal obligation to which We are  subject, or in order to protect Your vital interests or the vital interests of another  natural person. 

2.3 Please do not supply any other person’s personal data to Us unless We prompt  You to do so. 

3. Sharing Your personal data with others 

3.1 We may disclose Your personal data to any member of Our group of  companies (this means Our subsidiaries, Our ultimate holding company and all its  subsidiaries) (together known as “Group Companies”) insofar as reasonably  necessary for the purposes, and on the legal bases, set out in this policy. 

3.2 We may disclose Your personal data to Our insurers and/or professional  advisers insofar as reasonably necessary for the purposes of obtaining or  maintaining insurance coverage, managing risks, obtaining professional advice, or 

the establishment, exercise or defence of legal claims, whether in court proceedings  or in an administrative or out-of-court procedure. 

3.3 In addition to the specific disclosures of personal data set out in this Section 3,  We may disclose Your personal data where such disclosure is necessary for  compliance with a binding legal obligation arising under EU law to which We are  subject, or in order to protect Your vital interests or the vital interests of another  natural person. We may also disclose Your personal data where such disclosure is  necessary for the establishment, exercise or defence of legal claims, whether in  court proceedings or in an administrative or out-of-court procedure. 

4. International transfers of Your personal data 

4.1 You acknowledge that personal data that You submit for publication through  Our website or services may be available, via the internet, around the world. We  cannot prevent the use (or misuse) of such personal data by others. 

5. Retaining and deleting personal data 

5.1 This Section 5 sets out Our data retention policies and procedure, which are  designed to help ensure that We comply with Our legal obligations in relation to the  retention and deletion of personal data. 

5.2 Personal data that we process for any purpose or purposes shall not be kept  for longer than is necessary for that purpose or those purposes. 

5.3 Notwithstanding the other provisions of this Section 5, We may retain Your  personal data where such retention is necessary for compliance with a legal  obligation to which We are subject, or in order to protect Your vital interests or the  vital interests of another natural person.

6. Cookies 

6.1 By using Our website and agreeing to this policy, You consent to Our use of  cookies in accordance with the terms of Our Cookie Policy. 

7. The Rights of Data Subjects 

7.1 In this Section 7, We have summarised the rights that You have under data  protection law. Some of the rights are complex, and not all of the details have been  included in Our summaries. Accordingly, You should read the relevant laws and  guidance from the regulatory authorities for a full explanation of these rights. 

7.2 Your principal rights under data protection law are: 

1. The right to be informed
2. the right to access
3. the right to rectification
4. the right to erasure
5. the right to restrict processing
6. the right to object to processing
7. the right to data portability
8. Rights related to automated decision making including profiling
9. the right to complain to a supervisory authority; and
10. the right to withdraw consent.

7.2.1 The Right to be Informed 

This is the right of Data Subjects to know details regarding the processing of their  data and this information is included in this Privacy Policy 

7.2.2 The Right To Access 

 You have the right to confirmation as to whether or not We process Your  personal data and, where We do, access to the personal data, together with certain  additional information. That additional information includes details of the purposes of  the processing, the categories of personal data concerned and the recipients of the  personal data. Providing the rights and freedoms of others are not affected, We will  supply to You a copy of Your personal data upon request and within one month of  verification of Your identity (We may extend the time within which We must provide  the information by a further two months if the request is particularly complex or if  there are numerous requests and We will let You know if this is the case. The first 

copy will be provided free of charge, but additional copies may be subject to a  reasonable fee. 

7.2.3 The Right to Rectification 

 You have the right to have any inaccurate personal data about You rectified  and, taking into account the purposes of the processing, to have any incomplete  personal data about You completed. If the request is accepted by Us, the  rectification will be completed within one month (may be extended by Us by a further  two months if complex). 

 We will use all reasonable endeavours to notify any third party with whom we  have shared the data of any rectifications made. 

7.2.4 The Right to Erasure (also known as the “Right to be Forgotten”) 

 In some circumstances You have the right to the erasure of Your personal data  without undue delay. Those circumstances include: 

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• You withdraw consent to consent-based processing;
• You object to the processing under certain rules of applicable data protection law and there is no over-riding legitimate interest for continuing the processing;
• the processing is for direct marketing purposes;
• the personal data has to be erased to comply with a legal obligation; and • the personal data have been unlawfully processed.

However, there are exclusions of the right to erasure. The general exclusions include  where processing is necessary: 

• For exercising the right of freedom of expression and information;
• for compliance with a legal obligation for the performance of a public interest task or exercise of official authority;
• for archiving purposes in the public interest, scientific research or historical purposes; or • for the establishment, exercise or defence of legal claims.

 We will use all reasonable endeavours to notify any third party with whom we  have shared the data of any actioned erasure requests. 

7.2.5 The Right to Restrict Processing 

 In some circumstances You have the right to restrict the processing of Your  personal data. Those circumstances are:

• You contest the accuracy of the personal data (We will restrict processing for a period enabling Us to verify the accuracy of such data);
• processing is unlawful but You oppose erasure;
• Where You have objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and We are considering whether Our organisation’s legitimate grounds override those of the individual; 
• We no longer need the personal data for the purposes of Our processing, but You require personal data for the establishment, exercise or defence of legal claims;

 Where processing has been restricted we may continue to store Your personal  data. However, We will only otherwise process it: with Your consent or for the  establishment, exercise or defence of legal claims; for the protection of the rights of  another natural or legal person; or for reasons of important public interest. 

 We will use all reasonable endeavours to notify any third party with whom we  have shared the data of any restriction placed on the processing of Your data. 

7.2.6 The Right to Object to Processing 

 You have the right to object to Our processing of Your personal data on  grounds relating to Your particular situation, but only to the extent that the legal basis  for the processing is that the processing is necessary for: 

• The performance of a task carried out in the public interest or in the exercise of any official authority vested in Us (including profiling);
• the purposes of the legitimate interests pursued by Us or by a third party; • direct marketing (including profiling); or
• purposes of scientific/historical research and statistics

 If You make such an objection, we will cease to process the personal  information unless We can demonstrate compelling legitimate grounds for the  processing which override Your interests, rights and freedoms, or the processing is  for the establishment, exercise or defence of legal claims. 

7.2.7 The Right to Data Portability 

 To the extent that the legal basis for Our processing of Your personal data is: (a) consent; or 

(b) that the processing is necessary for the performance of a contract to which You  are party or in order to take steps at Your request prior to entering into a contract  and

(c) such processing is carried out by automated means, 

You have the right to receive Your personal data from Us in a structured, commonly  used and machine-readable format. However, this right does not apply where it  would adversely affect the rights and freedoms of others. 

7.2.8 Rights related to automated decision making including profiling. 

 We do not use automated decision making (including profiling) when processing  your data. 

7.2.9 Right to Complain. 

 If You consider that Our processing of Your personal information infringes data  protection laws, You should first contact Us. If You are dissatisfied with the  outcome, You have a legal right to lodge a complaint with a Supervisory Authority  responsible for data protection. You may do so in the EU member state of Your  habitual residence, Your place of work or the place of the alleged infringement. 

7.1.10 Right to Withdraw Consent 

 To the extent that the legal basis for Our processing of Your personal  information is consent, You have the right to withdraw that consent at any time.  Withdrawal will not affect the lawfulness of processing before the withdrawal. To  withdraw Your consent, please contact Our Us. 

7.13 You may exercise any of Your rights in relation to Your personal data by written  notice to Us. 

8. Contacting Us concerning the contents of this Privacy Policy 

8.1 If Your query relates to this Privacy Policy or should you wish to exercise one  of Your Data Protection Rights as a Data Subject, You can contact Us in the  following ways: 

By post to Our registered office 

By email at: info@oxygen-sces.com

By telephone on: +971 55 3310493 

9. Amendments to this policy 

9.1 We may update this policy from time to time by publishing a new version on  Our website. 

9.2 You should check this page occasionally to ensure You are happy with any  changes to this policy. 

9.3 We may notify You of changes to this policy by email. 

This policy was last updated on 23 January 2021 

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: 

(i) Prospect Global Ltd (trading as SoPro) Reg. UK Co. 09648733. You can contact  SoPro and view their privacy policy here: http://sopro.io. SoPro are registered with the ICO  Reg: Z123456 their Data Protection Officer can be emailed at: dpo@sopro.io.