(Updated 24 May 2018)
We at Oxford Computer Group Worldwide, trading as OCG Learning and Oxford Computer Training, are committed to protecting the privacy of our website users, customers and prospective customers.
- We will never sell, rent or otherwise disclose your personal data to any third party except where it is necessary to provide you with services you have requested, and only then for that purpose.
- We will protect your personal data against loss and unauthorised access using appropriate security measures.
- You can unsubscribe from marketing communications at any time, either by clicking the unsubscribe button at the bottom of marketing emails, or by sending an email to firstname.lastname@example.org.
- You can ask us to let you know what personal information we hold about you, and ask for it to be deleted.
If you have any questions, please don’t hesitate to contact us:
- Email: email@example.com
- Telephone: +44 (0) 1865 521200
- Post : OCG Learning/Oxford Computer Training, Unit 3, Corner Farm, Oakley Road, Horton-cum-Studley, Oxford OX33 IBJ, UK
Introduction | How we use your personal data | Profiling | Providing your personal data to others | Extra-EEA transfers of your personal data | Retaining and deleting personal data | Security of personal data | Amendments | Your rights | Third party websites | Personal data of children | Updating information | About cookies | Cookies that we use | Cookies used by our service providers | Managing cookies | Our details
1.1 We are committed to safeguarding the privacy of visitors to our website at www.ocglearning.com, our prospective customers and our customers.
1.2 In this policy, “we”, “us” and “our” refer to Oxford Computer Group Worldwide Ltd, also known as OCG Learning and Oxford Computer Training. We are the training arm of Oxford Computer Group, a group of companies that share a common brand and values, and that specialise in identity lifecycle management, identity-driven security, and identity governance.
1.3 In addition to offering industry-leading training courses, we develop and licence tools to support identity management projects, and offer webinars, blogs and whitepapers to enable IT professionals to keep up to date with our services, the latest technologies and best practices. For more information about us, see Section 17.
1.4 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 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 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.
2.3 We may process information relating to our relationships with customers and prospective customers, including contact information, payment preferences, job/role information, information about attendance at courses and assessment results relating to such courses (“prospective customer data” and “customer data“). This data may be processed for the purposes of operating and maintaining our website, managing our relationships with customers and prospective customers, facilitating orders and bookings, communicating with customers and prospective customers, keeping records of those communications and promoting, marketing and selling our services, and those of our group of companies, to customers and prospective customers. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and the management of our customer relationships.
2.4 We may process information relating to transactions, including orders for our software tools and bookings for training courses and events made through our website (“order and booking data“). The order and booking data may include your name, your contact details and transaction-specific details such as the date of the transaction and the details of the order or booking. Although the order and booking data will usually be obtained from you, it may also be supplied by a person making a booking on your behalf. The order and booking data may be processed for the purpose of supplying the purchased software tools and services, communicating with you in relation to the order or booking, managing bookings generally and keeping proper records of transactions. The legal basis for this processing is:
(a) the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; and/or
(b) our legitimate interests, namely the supply of our software tools and services and the proper administration of our website and business.
2.5 We may process information contained in or relating to any communication that you send to us (“communications data“). The communications data may include 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 communications 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 customers, prospective customers and users.
2.6 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. 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.
2.7 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. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.8 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.
2.9 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3.1 We may analyse your personal data to create a profile of your likely interests and preferences. We may use the profile to determine whether to send you communications, and the content of such communications.
3.2 We may make use of additional information about you when it is available from external sources to help us do this effectively (such as information on your or your employer’s website).
4. Providing your personal data to others
4.1 We will not sell, rent or otherwise disclose your personal data to any third party for their marketing purposes without your express consent.
4.2 We may disclose your personal data to Oxford Computer Group in the USA and other members of our group of companies (this means those companies operating under the Oxford Computer Group brand) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.3 We may disclose your personal data to our service providers and subcontractors (including our website hosting services providers, our marketing database providers, our webinar providers, and our order and payment services providers) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. The services providers and subcontractors include Microsoft O365, Stripe, Hubspot, Logmein (Gotowebinar), coopa.net, Xtreme, EasyLMS and Locklizard. Please contact us for the most up-to-date list, if required.
4.4 We do not store any of your card details or other sensitive financial information. Financial transactions relating to our website and services are handled by our payment services provider, Stripe, Inc. We will share transaction data with our payment services provider only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services provider’s privacy policies and practices at https://stripe.com/gb/privacy.
4.5 We may disclose details of your training course and event bookings to event and venue operators and to other third party services providers for the purpose of enabling those third parties to provide their services to you.
4.6 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.
4.7 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure 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. 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.
5. Extra-EEA transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 We and our other group companies have offices and facilities in the USA, as well as within the EEA. Any transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
5.3 Some of our services providers and subcontractors use facilities situated outside the EEA. Subject to Section 5.4, we will ensure that all extra-EEA transfers to services providers and subcontractors are either:
(a) to jurisdictions that provide adequate protection for personal data; or
(b) are protected by appropriate safeguards, namely the standard contractual clauses approved by the European Commission, the Privacy Shield scheme and/or binding corporate rules.
Please contact us if you would like details of the appropriate safeguards we use.
5.4 If you book or are booked to attend a training course or event outside the EEA, then we will send your name together with selected account and customer data on a need to know basis to relevant event and venue operators and to other third party services providers situated outside the EEA in order for them to provide services to you. By booking you acknowledge that transfers made under this Section 5.4 may not be protected by appropriate safeguards.
6. Retaining and deleting personal data
6.1 This Section 6 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.
6.2 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.
6.3 We will retain your personal data as follows:
(a) usage data will be retained for a minimum period of 30 months following collection;
(b) prospective customer data will be retained for a maximum period of 18 months following our last interaction with the prospective customer;
(c) customer data will be retained for a minimum period of 6 years following the end of the year during which the last contract between us and the customer terminated or expired, and for a maximum period of 7 years following that date;
(d) order and booking data will be retained for a minimum period of 6 years following the end of the year during which the relevant transaction occurred, and for a maximum period of 7 years following that date; and
(e) communications data (excluding data which is also prospective customer data or customer data) will be retained for a maximum period of 3 years following the end of the year in which the communication occurred.
6.4 Notwithstanding the other provisions of this Section 6, 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.
7. Security of personal data
7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 Please check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may notify you of significant changes to this policy by email or via our website.
9. Your rights
9.1 In this Section 9, 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.
9.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
9.3 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. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
9.4 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.
9.5 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; the processing is for direct marketing purposes; 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; or for the establishment, exercise or defence of legal claims.
9.6 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; processing is unlawful but you oppose erasure; 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; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; 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.
9.7 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; or the purposes of the legitimate interests pursued by us or by a third party. 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.
9.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
9.10 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 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.
9.11 If you consider that our processing of your personal information infringes data protection laws, 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.
9.12 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.
9.13 You may exercise any of your rights in relation to your personal data by written notice to us.
10. Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11. Personal data of children
11.1 Our websites and services are targeted at persons over the age of 16.
11.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
12. Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13. About cookies
13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
14. Cookies that we use
15. Cookies used by our services providers
16. Managing cookies
16.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
16.2 Blocking all cookies will have a negative impact upon the usability of many websites.
16.3 If you block cookies, you will not be able to use all the features on our website.
17. Our details
17.1 This website is owned and operated by Oxford Computer Group Worldwide Ltd, which also trades as OCG Learning and Oxford Computer Training.
17.2 We are registered in England and Wales under registration number 9504108, and our registered office is at Corner Farm, Oakley Road, Horton-cum-Studley, Oxford, Oxfordshire, OX33 1BJ, UK.
17.3 You can contact us:
(a) by post, to OCG Learning/Oxford Computer Training, Unit 3, Corner Farm, Oakley Road, Horton-cum-Studley, Oxford OX33 IBJ, UK;
(b) by telephone, on +44 (0) 1865 521200; or
(c) by email, using firstname.lastname@example.org.