OXFORD GLOBAL PRIVACY POLICY
1. IMPORTANT INFORMATION ABOUT THIS POLICY
Oxford Global Marketing Limited (“Oxford Global”, "we", "our", "us") is a company registered in England and Wales (company number: 06408327 and registered office address: Highview House 1st Floor, Tattenham Crescent, Epsom, Surrey, KT18 5QJ) and our main trading address is 2nd Floor Godstow Court, Minns Business Park, Botley, Oxford, OX2 0JB.
We take your privacy rights seriously and handling your data legally and fairly at all times is a priority at Oxford Global. This privacy policy (“policy”) sets out how we look after your personal data, your privacy rights and how the law protects you.
Oxford Global is the controller of personal data collected and processed in accordance with this policy. If you have any questions about this policy, including any requests to exercise your legal rights please contact us either via post at our main trading address set out above or email at: help@oxfordglobal.co.uk
We have designed this policy so you can easily find and access the information that is most relevant to you by the use of clearly worded headings that you can click on to directly access the information you are looking for.
This policy applies to personal data collected when you:
• visit our websites: www.oxfordglobal.com and https://lifescienceXchange.com ("websites"):
• register to, and/or purchase, our products, services and/or publications including creating an account with us;
• sign up to receive our newsletter, new articles and marketing communications or register for one of our events;
• contact us, for example by telephone, email, post, or submitting the “Get in Touch” form on our websites;
• provide products and/or services to us;
• visit our premises;
• apply for a job with us.
Please read this policy carefully as it explains how we use personal data. We keep this policy under regular review and may make changes from time to time, and when we do, we update this page, so please check back frequently.
It is important that the personal data we hold about you is accurate and current. We may ask you to confirm updates to your personal data from time to time but please keep us informed if your personal data changes during your relationship with us in the meantime. Please inform us of any changes in your data at: help@oxfordglobal.co.uk.
Our website is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This policy supplements the other notices and is not intended to override them.
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information describing or relating to an identified or identifiable individual. It does not include data where the identity has been removed (i.e. anonymous data). We collect, use, store and transfer the different kinds of personal data about you set out below:
• Identity Data includes name, title, photograph, job title and name of employer (i.e. company).
• Contact Data includes business address (including billing and, delivery, as well as country), and business email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of products and/or services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our websites, products, services and/or publications.
• Marketing, Events and Communications Data includes your preferences in receiving marketing, including newsletters, or attending one of our events from us and our third parties (including our event (including in-person and online) sponsors and media partners and associations) and your communication preferences.
• Tracking Data includes unique tags issued to event attendees on lanyards that are used for tracking entry, exit and session participation, and other event-related activities.
• Call Recordings includes (where we interact with you by phone) recordings of calls.
• Recruitment Data includes relevant Identity and Contact Data (as well as residential address, personal email and contact details), details of your qualifications, experience and education, CV, employment history, interview notes/information, references, assessment results, and any other personal data which you chose to disclose to us during the recruitment process whether verbally or in written/electronic form.
Information you provide to us for the purpose of attending one of our events, including diestray requirements, may reveal information about your health or religious beliefs, which is referred to as "special category" or "sensitive" data. to the extent we process any such data relating to you, we will do so because your provide it to us when you register for the event and have given us your explicit consent to process it.
Apart from personal data relating to you, if you provide us with the personal information of any third parties, before you provide such third-party personal information to us, you must first inform these third parties of any such information which you intend to provide to us and of the processing that we will carry out, as detailed in this policy.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
Personal data that we receive about you from other sources
Where you purchase a product or service from us, we may receive information (including Transaction Data) about you from third party providers of technical, payment and delivery services,
We may receive business contact details from third-party data brokers and aggregators.
Where you apply for a job with us, we may obtain some information from third parties, for example, when we seek references from your previous employers and other referees.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect personal data from and about you including through:
• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• create an account;
• register to our service or publications;
• purchase our products and/or services;
• request marketing to be sent to you;
• enter a competition or prize draws;
• complete a survey or provide a review;
• attend an event (e.g. webinar, conference (whether in person or remotely));
• give us feedback or contact us, by phone, email, our “Contact Us” or “Get in Touch” forms or otherwise.
• Automated technologies or interactions. As you interact with our website, and where you have provided your consent (as applicable), we collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. For further information about what cookies we use, please see our Cookie Policy .
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties (where you have provided your consent (as applicable): (i) analytics providers, such as Google (Google Analytics), (ii) advertising networks such as Google (Google Ads and Adwords) and LinkedIn, and (iii) search information providers;
• Contact and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from data brokers or aggregators, such as Cognism, Evaboot and Prodeets.
• Identity and Contact Data from publicly availably sources.
4. HOW WE USE YOUR PERSONAL DATA AND WHAT IS OUR LEGAL BASIS FOR USING IT
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
· Performance of a contract with you: Where we need to perform a contract we are about to enter into, or have entered into, with you. For us to fulfil our obligations under such contract (e.g. to allow you to purchase products and/or services from us), we will need to collect and process your personal data.
· Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to.
· Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Generally, we do not rely on consent as a legal basis for processing your personal data. If, in exceptional circumstances, we carry out processing based on your consent, we will make it clear at the time.
We set out in the table below a description of how we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are (where applicable).
Purpose/Activity Type of personal data Lawful basis for processing (including, where applicable basis of legitimate interest)
To create an account with us and register you as a customer (a) Identity
(b) Contact Performance of a contract with you
To provide our products and/or services in accordance with the contract between us, including processing and delivering orders, managing payments, fees and charges, sending invoices and payment reminders, collecting and recovering money owed to us, and other general contract administration (a) Identity
(b) Contact
(c) Transaction (a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts due to us and manage our business in a commercially effective manner.
To manage our relationship with you including: (i) dealing with your enquiries, requests, complaints and queries, and (ii) notifying you of changes to our terms or privacy policy
(a) Identity
(b) Contact
(c) Transaction
(d) Profile
(e) Marketing, Events and Communications (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to respond to any correspondence or queries you send us, and keep our records updated and help us better understand and communicate with our customers.
To send you relevant marketing communications and make personalised suggestions and recommendations to you about our products or services that may be of interest to you based on your Profile Data and (where you register to attend one of our events) to cmmunicate with you about the event including providing you with news/updates/important information in connection with the event (a) Identity
(b) Contact
(c) Transaction
(d) Profile
(e) Usage
(f) Marketing, Events and Communications
Where required by law, your consent or where information is solicited. Otherwise, this processing is necessary for our legitimate interests to carry out marketing, develop our products and services and grow our business including via events we organise, host or sponsor.
To enable you to partake in a prize draw or competition (d) Identity
(e) Contact
(c) Profile
(d) Usage
(e) Marketing, Events and Communications (a) Performance of a contract with you
(b) Necessary for our legitimate interests to help us better understand our customers via their interactions with us and information provided during their involvement in our prize draws and competitions, as well as fostering good relations with our customers.
To carry out market research through your voluntary participation in surveys (a) Identity
(b) Contact
(c) Profile This processing is necessary for our legitimate interests to help us better understand our customers via their interactions with us and information provided during their involvement in our surveys, to study how our products and services are used to develop our product/service offerings and grow our business.
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical (a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing, Events and Communications
(f) Technical
(g) Tracking Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, publications, marketing, customer relationships and experiences (a) Technical
(b) Usage
(c) Tracking
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and inform our marketing strategy
When you apply for a job with us to consider your suitability for the role you applied for, compare you to other candidates and make recruitment decisions (a) Identity
(b) Contact
(c) Recruitment (a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests in fully assessing job candidates to ensure that only suitable and appropriate candidates are selected, to compare candidates and make fair decisions on the most appropriate candidate for the role.
When you provide us with products and/or services (including support, maintenance and other associated services) including ordering and making payments, and other general contract administration (a) Identity
(b) Contact (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests in conducting our business, including ordering and paying services and good contract management.
For training and quality control purposes we record calls Call recordings This processing is necessary for our legitimate interests to collect information from customers/prospective customers: (i) for training purposes, (ii) for continuous product/service improvement purposes, (iii) for quality control purposes, and (iv) to better understand our customers/prospective customers, their experiences of our products/services and their preferences, to help shape future business decisions.
To comply with laws and regulations applicable to Oxford Global Potentially all data types This processing is necessary for the compliance with legal obligations and regulations which Oxford Global is subject
In connection with any merger, sale, transfer of our assets, investment, acquisition, bankruptcy or similar event or corporate transaction Potentially all data types This processing is necessary for our legitimate interests to ensure we can protect and grow our business.
5. WHO DO WE SHARE PERSONAL DATA WITH
Within Oxford Global, your personal data can be accessed by or may be disclosed internally on a need-to-know basis, for example, to members of our HR team involved in recruitment, our customer services team, management team, IT security, systems administrators, members of our finance teams etc,
Your personal data is also accessed by those categories of third parties set out in the table below for the purposes set out in section 4 (How we use personal data and what is our legal basis for using it).
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Category of recipients Details of disclosure
External We engage the following third-party service providers, suppliers and vendors from time to time (some as our processors):
• to assist us provide our products and/or services, assist with customer management, and process personal data on our behalf, including third parties that provide online platform hosting services, IT and system administration services, customer relationship management systems and email distribution, website service providers;
• to process payments, payment and invoicing platform providers;
• to help us improve and optimise our products and services, analytics and search engine providers;
• to help us locate suitable job candidates for vacancies, recruitment agencies;
• to help us organise events, where you attend an event hosted or sponsored by us, event organisers, event venue suppliers and logistics companies in connection with the event;
• to the extent we require assistance with our legal/regulatory obligations, other legal/regulatory matters, insurance and banking matters, professional advisors including lawyers, bankers, auditors, accountants, insurance providers.
External We may disclose personal data if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process (including to law enforcement or competent authorities like the police and tax authorities).
External Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Some or all personal information set out above may be disclosed in the case of a corporate transaction. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this policy.
Internal Our group company based in the US, which provides sales, IT and system administration services on our behalf.
6. INTERNATIONAL TRANSFER OF PERSONAL DATA
We share your personal data within the Oxford Global Group. This will involve transferring your data outside the UK.
We also transfer personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.
Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place (as applicable):
· we will only transfer personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.
· we will only transfer personal data to companies in the USA that have an active registration with the EU-US Data Privacy Framework; or
· we may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us at the contact details set out in section 12 (Contact Us) below.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. However, some personal data may be retained for varying time periods to comply with legal and regulatory obligations and for legitimate business reasons. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see section 10 (Your Legal Rights) below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can manage your marketing preferences or opt out of marketing at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products and/or services from us or if you provided us with your details when you signed up for an event, entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside of Oxford Global for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us using the details set out in section 12 (Contact Us) at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please refer to our Cookie Policy .
10. YOUR LEGAL RIGHTS
Depending on the circumstances, you have a number of rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (i.e. a "data subject access request" or “DSAR”) This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your information (including carrying out profiling based on our legitimate interests) In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see section 9 (Marketing) for details of how to object to receiving email marketing communications).
Request the transfer of your personal data to you or to a third party (where applicable) This will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(Where applicable) withdraw consent at any time where we are relying on consent to process your personal data Where this is applicable, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the accuracy of the data;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to make a complaint at any time to the Information Commissioner (ICO) See section 12. (Contact Us) below for further details.
If you wish to exercise any of the rights set out above, please contact us at the contact details provided in section 12.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. THIRD-PARTY LINKS
Our website may from time to time include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
We (including our brands: Discovery & Development, NextGen Biomed, Precision Medicine and LifescienceXchange) have a social media presence for the purpose of engaging with you. If you enable such connections or choose to communicate your personal data to us via third-party websites or social media, please remember that we do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or interact with us on social media, we encourage you to read the privacy policy of every website of forum that you visit or use.
12. CONTACT US
If you have any questions about this policy or about the use of your personal data or you want to exercise any of your legal rights, please contact us at: help@oxfordglobal.co.uk.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.