We’ve updated this website’s privacy notice to reflect a new data privacy law – the General Data Protection Regulation, or GDPR.
This doesn’t mean that we’re changing the way that we collect or use your personal information when you use this website, but we’ve made clearer to you the information that we collect, how we collect it, what we do with it, and your rights relating to your personal information.
Please don’t hesitate to contact us if you have any questions about the updated privacy notice.
CPP Assistance Services Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how CPP Assistance Services Limited looks after your personal data when you visit its website at www.owldetect.com (“Site”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how CPP Assistance Services Limited collects and processes your personal data through your use of this Site, including any data you may provide to it.
This Site is not intended for children and CPP Assistance Services Limited does not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice CPP Assistance Services Limited may provide on specific occasions when it is collecting or processing personal data about you so that you are fully aware of how and why it is using your data. This privacy notice supplements the other notices and is not intended to override them.
CPP Assistance Services Limited is the controller and responsible for your personal data (referred to as "we", "us" or "our" in this privacy notice).
We are a company registered in England and Wales under company number 03180887. Our registered office is 6 East Parade, Leeds, United Kingdom, LS1 2AD. We are part of the CPPGroup Plc group of companies (“CPP Group”).
You can contact us:
- by post at: The UK Compliance Team, CPP Assistance Services Limited, Holgate Park, York, YO26 4GA;
- by phone on: 0330 123 0306 (8am - 6pm Monday to Friday and 9am-1pm Saturday) Calls cost no more than calls to geographical numbers (01 or 02) and will be included as part of inclusive minutes in your package; or
- by email at: firstname.lastname@example.org
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
You can contact the DPO:
- by post at: Data Protection Officer, CPP Assistance Services Limited, Holgate Park, York, YO26 4GA; or
- by email at: DataPrivacy@cpp.co.uk
Changes to the privacy notice and your duty to inform us of changes
We may change this privacy notice from time to time by updating this page. We will not necessarily bring changes or updates to your attention so please revisit this page periodically to re-read this privacy statement and to ensure you are aware of any changes when you visit the Site. If there are substantive changes, we may at our discretion bring those to your attention, for example, by a message posted on the landing page of the Site.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This Site may include links to third-party websites, which may include websites provided by other companies within the CPP Group. Clicking on those links may allow these third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We will process the personal data that we collect from you in accordance with this privacy notice.
For holders of an OwlDetect subscription (a “Subscriber”), or administrators or employees of a firm or organisation Subscriber, we will also process personal data we collect from you in accordance with the Privacy Notice in the terms and conditions which apply to the OwlDetect subscription (“OwlDetect Terms”). This will include where you use the secure customer area (“Subscribers’ Area”).
In particular, we may use information we hold about you:
· for the purposes of processing, providing you with and managing your OwlDetect subscription;
- to collect payments when due (if applicable); and
- if you have agreed, either when purchasing or registering for an OwlDetect subscription or during your subscription, to provide you with information about our products, promotions and special offers provided by us or other members of our group of companies that we believe may be of interest to you. Depending on your selected preferences, such communication may occur by email or SMS. See the Privacy Notice contained within the OwlDetect Terms for more information.
When using the Site, whether you are an OwlDetect Subscriber or other Site user, we may collect and process the following data about you:
•Information you give us. This may include:
- contact details you may provide to support a query you raise using the ‘contact us’ form e.g. service queries or billing enquiry.
- login credentials such as email address and password used for accessing the Subscribers’ Area of the Site.
•Information we automatically collect about you (including if you use the Subscribers’ Area).
This may include:
- technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, the type of device you are using to access the Site, resolution of the screen and operating system; and
- information about your visit such as whether you have visited the Site before and information collected through the use of Google Analytics which is anonymised. The CPP Group collects statistical information such as the number of visitors to certain areas of the Site during a given period. This information is collected for statistical review only and it cannot be used to identify an individual user.
If you fail to provide personal data
Where we need to collect and use personal information by law, or where you are accessing the Subscribers’ Area, and you fail to provide that information when requested, we may not be able to perform the contract for the OwlDetect subscription.
Where we need to collect and use your personal information in order to respond to a query you have raised through the ‘Contact Us’ form on the Site, and you fail to provide that information when requested, we may not be able to respond to you and/or action your request.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions You may submit personal data (such as your contact details) by filling in the ‘Contact Us’ form on the Site or by corresponding with us by phone, e-mail or otherwise
4. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data collected on the Site (excluding the Subscribers’ Area – see the Privacy Notice contained within the OwlDetect Terms for a description of this), and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Lawful basis for processing including basis of legitimate interest
To provide you with access to the Subscribers’ Area if applicable
Performance of the contract for the OwlDetect subscription
To contact you regarding any specific enquiry you make
(a) Performance of the contract for the OwlDetect subscription
(b) Necessary for our legitimate interests (for running our business, to develop our business)
Internal record keeping
(a) Necessary for our legitimate interests (for running our business)
(b) Necessary to comply with a legal obligation
To improve our products and services
Necessary for our legitimate interests (to develop our business and inform our marketing strategy)
Necessary for our legitimate interests (to study statistical trends within the business, to develop our business and inform our marketing strategy)
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above :
Your personal information will be made available to our authorised service providers (which will include other companies within the CPP Group which provide services to us) and third party suppliers which perform certain services on our behalf e.g. providing IT support and maintenance, providing hosting services, providing online payment services and providing marketing services.
These service providers may have access to personal information needed to perform their functions on our behalf but are not permitted to share or to use such information for any other purpose. We require all third parties to respect the security of your personal information and to treat it in accordance with the law.
Other companies within the CPP Group
We may share limited personal information with other companies within the CPP Group e.g. to the extent needed for proper management and parental analysis and decision making.
We may also disclose your personal information:
o In response to a court order, or a request for cooperation from a law enforcement or other government agency;
o To establish or exercise our legal rights; to defend legal claims; or as otherwise required or permitted by applicable laws and/or regulations;
o When we believe that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding illegal activity, suspected fraud, or other wrongdoing; to protect and defend the rights, property or safety of CPP Assistance Services Limited, other CPP Group members, customers, staff, suppliers or others; to comply with applicable law or cooperate with law enforcement; or to enforce our terms or other agreements;
o To prospective or actual buyers in the event that we sell any of our business or assets, or to other CPP Group members in the event of a reorganisation.
We will not otherwise transfer, disclose, sell, distribute or lease your personal information to third parties unless we have your permission to do so or are otherwise required or permitted to do so by law.
6. International transfers
The GDPR permits the export of personal data to other countries subject to the provision of adequate levels of protection for the processing of such personal data. We will ensure that if we transfer your personal information outside the EEA, adequate safeguards are put in place to protect your personal information as data protection standards in those countries may differ from those in the EEA.
Please contact our Data Protection Officer on the contact details set out in section 1 of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We align and adhere to applicable industry standards i.e. Payment Card Industry Data Security Standard (PCI DSS), demonstrating how we effectively secure your data when we process, store and transmit this information on behalf of our customers and business partners.
We are continually reviewing and updating our security procedures as new technologies become available. All areas of the OwlDetect website where personal information is collected are secure and your browser will display the ‘padlock’ symbol for reassurance. Where information is transferred it will be encrypted.
8. Data retention
How long will you use my personal data for?
We will retain your personal information collected on the Site for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.
Where you have an OwlDetect subscription please see the Privacy Notice contained within your OwlDetect Terms for a description of how long we will retain your data.
9. Your legal rights
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. If you think any information we have about you is incorrect or incomplete, please contact us as soon as you can using the contact details set out below. We will correct or update any information as soon as possible.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information 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 information 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 information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, you can contact us:
- by post at: Data Protection Officer, CPP Assistance Services Limited, Holgate Park, Holgate Road, York, YO26 4GA
- by email at: DataPrivacy@cpp.co.uk
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
We will try to respond to all legitimate requests within one month. Occasionally it may 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.
You also have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority 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.