Working with Open Assets Privacy Policy
1. Introduction
This Privacy Policy (“Privacy Policy”), which includes our Cookie Policy, sets out the basis on which Open Applications Ltd. T/A Open Assets (“we”, “us”, “our”) will collect and process any data that may identify individuals’ (“personal data”) .
By personal data, we mean information which, either by itself or combined with other information that is available to us, can be used to identify you, your principals, directors, shareholders or anyone employed by you or engaged by you who may access our online systems. For the purpose of this Privacy Notice, where we refer to “you” or “your” this will also include your principals, directors, shareholders, employees, contractors and workers..
We will process such information in accordance with applicable data protection law including the EU General Data Protection Regulation (“GDPR”) (in force from 25 May 2018) and any national laws implementing GDPR. If you have any questions regarding this Privacy Policy please send an email to info@open-assets.co.uk
This Privacy Policy (“Policy”) is intended to inform you how your personal data is collected, used and disclosed through your use of the Open Assets Platform and website.
2. The information we collect
Personal data (Full Name, Email Address, Postal Addresses) will be collected when using of our services outlined below:
(a) Requesting system access to the Open Assets platform
(b) Allocating an Asset controller to an asset
(c) details of your visits to the Service, including the IP address used and the resources that you access (see also our Cookie Policy);
(d) information that you provide by filling in forms on the Service, posting User Content or requesting further services or reporting a problem;
3. Where we store your personal data
We currently store personal data sites across the UK, but you acknowledge and agree that it may also be transferred to and be stored at one or more destinations in the European Economic Area (“EEA”). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
Once we have received your personal data, we will use (and require our suppliers and partners to use) procedures and security features to try to prevent unauthorised access, unlawful processing, accidental loss or destruction of, or damage to it, provided that you comply with the provisions of the Customer Agreement relating to the security..
How long we keep your data
Unless a longer retention period is required or permitted by law, we will only hold your personal information on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request it is deleted.
With your consent, the information that we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information. When you receive marketing communications from us you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail.
4. The legal basis for processing your information
Under the GDPR, the main grounds that we rely upon in order to process your personal information are as follows:
a) Necessary for entering into, or performing, a contract – in order to perform obligations that we undertake in providing the Service, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;
b) Consent – in some circumstances, we may ask for your consent to process your information in a particular way. To the extent that we are processing your information based on your consent, you will have the right to withdraw your consent at any time. You can do this by contacting us at info@open-assets.co.uk at any time.
5. Disclosure of your information
We use a number of third party organisations to help provide a professional service to our customers. These organisations act as data processors and are strictly controlled in how they may/may not use your Information and we remain responsible for the protection of your Information. These organisations include:
Marketing companies (e.g. to help us to communicate with our customers)
Marketing analytics and website analytics companies (e.g. to help us monitor how users experience our platform and enabling us to make improvements over time)
We will never sell your information to a third party.
6. Your rights
In accordance with the GDPR, you have the following rights in respect of your personal information.
Right to access: the right to request copies of your personal information from us, and to confirm the nature of the information and how it is used;
Right to erase: the right to request that we delete or remove your personal information from our systems;
Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete;
Right to restrict our use of your information or to withdraw your consent for processing your information: the right to ‘block’ us from using your personal information or limit the way in which we can use it;
Right to object: the right to object to our use of your personal information;
You can exercise any of these rights by contacting us at info@open-assets.co.uk
We will aim to respond to all requests a 90 day period but will endeavour to repond sooner where possible. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your information, or certain parts of the request with a reason provided.
In some cases, the deletion of your data may contravene other regulations requirements and so will be retained, we shall inform you of such if this is the case.
7. Complaints
If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated.
Email – complaints@open-assets.co.uk
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office
This privacy notice was last updated on 28th September 2022.
We reserve the right to amend or modify this Privacy Policy at any time and any changes will be published on the Open Assets website and application with the date of the most recent revision.
Significant changes to this policy may also mean we notify you by other means such as email. Where required by law we will obtain your consent to make these changes.