In this notice, “Oxygen8” or “Oxygen8 Group” means Oxygen8 Communications. The purpose of this privacy notice is to inform you about what kinds of information we, at Oxygen8 Group, may gather about you, how we may use that information, whether we disclose it to anyone, and the choices you have regarding our use of the information. This notice forms part of the Oxygen8 Group Terms and Conditions.
This notice does not apply to the practices of companies that Oxygen8 Group does not own or control, or to people that Oxygen8 Group does not employ or manage. This includes any companies from whom you may have ordered services or products using the Oxygen8 Group service (“Merchants”), and any companies from whom you may be purchasing/using telecommunications services.
WHO ARE WE
Oxygen8 Group is incorporated and registered in England and Wales and whose registered office is at:
Oxygen8 Communications Ltd,
12th Floor Lyndon House,
58-62 Hagley Road,
If you have any questions or would like to make a request to exercise any of your legal rights, please contact our Data Protection Team using the contact information set out in the “Contact & Complaints” section below.
Oxygen8 Group will collect information from in the course of the following activities:
- When you participate in any Oxygen8 Group service and we process your transactions (whether via your mobile phone or the internet, or other media) we will use the personal information you have provided (including but not limited to your mobile phone number and/or your email address or postal address, network information or computer data) to provide you with the service; and promotions or further information regarding our products and services should you indicate your consent in the marketing preferences;
- When you correspond with Oxygen8 Group for example, by subscribing to our newsletter or to apply for work with us, we will use your contact information to keep you up to date with information regarding our company and work opportunities;
- When you contact Customer Support through our web site or by telephoning the support number, we may ask you for personally identifiable information regarding your inquiry, such as your name, email address, telephone number, purchases or telephone records;
- When you visit the Oxygen8 Group website we automatically collect information about your visit to help us ensure that each visitor to our website can use and navigate the site effectively. This information may include the internet protocol (IP) address used to connect your device to the internet, uniform resource locators (URLs) clickstream to, through and from our site, browser type and version, browser plug-in types and versions, operating system and platform.
Please note we do not collect information about the following;
We do not collect any “Special Categories of Personal Data” about you (e.g. ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership or biometric data). Nor do we collect information about criminal convictions and offences.
We do not collect data regarding children and our Services are not aimed at or intended for the use of anyone below the age of 18 years old.
Under the General Data Protection Regulations Oxygen8 Group is allowed to use your personal data only where there is a proper reason to do. Legally, Oxygen8 Group must have one or more reasons and these are:
- Contract – where your personal information is processed to fulfil a contractual obligation
- Consent – where you agree to Oxygen8 Group or the Merchant using your information this way
- Legitimate Interests – this means the interests of Oxygen8 Group in managing our business to allow us to provide you with the best services in the most secure and appropriate way e.g. transferring your data to third parties such as a Mobile Network Operator for text alert purposes
- Legal Obligation – where there is statutory or other legal requirements to share the information e.g. when Oxygen8 Group must provide your information for law enforcement purposes.
Oxygen8 Group collects and uses your personal information to give you high quality customer service, to provide you with convenient access to our products and services, and to make you aware of the latest offerings from Oxygen8 Group. To the extent permitted by law, Oxygen8 Group may aggregate your personal information with other third party data to enhance demographic profiles or to achieve regulatory compliance.
When we process data on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:
- The purpose test – is there a legitimate interest behind the processing?
- Necessity test – is the processing necessary for that purpose?
- Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights or freedom?
Please find below a list of the types of personal data we process, the reason why we process that data and the lawful basis for that processing.
|Type of data collected||Lawful basis for processing||Oxygen8 Group’s purpose of collection|
(Name, mobile phone number, email address, services or products availed of using the Oxygen8 Group service)
|To process purchase transactions for products and services on behalf of our clients (Merchants), and any companies from whom you may be purchasing / using telecommunications services.
To ensure any transaction issues can be dealt with.
For accounting and taxation purposes.
Documentation should any contractual legal claim arise.
|Customer Account Details
(Name, email address, mobile phone number)
Legal obligation/ Legitimate interests (depending on nature of services)
|Keeping our records up to date, providing you with efficient customer service and working out which of our products and services may interest you and telling you about them.
To provide you with access to your billing / purchase history
(technical information such as IP addresss, operating system and platform, browser type, etc)
|Legal Obligation / legitimate interests
|To detect, investigate and report financial crime (e.g. Fraud) and to comply with any legal and regulatory obligations placed on us by regulators such as the PFI. Process efficiency in dealing with such activity, and to make service and process improvements.|
(IP addresss, operating system and platform, browser type, etc)
|Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites.|
|Contact Information and Marketing Preferences
(Name, email address, mobile number, etc)
|To provide you with information about special offers, promotions, new products and services that might be of interest to you. Provide you with online advertising and updates in relation to the identified area of interest.
To communicate with you about any issues or queries raised with Customer Services.
SHARING OF YOUR PERSONAL DATA
Oxygen8 Group may share your personal data including transaction data with its Merchants, our affiliates, agents and your mobile network operator (“Network”), law enforcement agencies or other third parties as necessary for the fulfillment of its service obligations (including matters in relation to the goods and services supplied by these parties) or for the purposes of legal compliance (including investigations, pursuant to court orders or analogous activities), the prevention of fraud or misuse, for the purposes of a corporate transaction or as may be otherwise permitted by law. The Merchants, affiliates and agents may be located outside of the European Economic Area. We contractually require Merchants to restrict the use of your personal information and maintain its confidentiality and Wherever transfers of data to third counties occurs Oxygen8 Group will put in place appropriate contractual provisions to ensure that there are strict rules regarding both the confidentiality and security of your information.
We limit access to your personally identifiable information to employees and Merchants and Networks who we believe need access in order to provide services to you or to do their jobs or as described in this notice. Merchants may use your personal information after you have made a purchase from them in order to promote their services and products. If you wish to opt-out of receiving such marketing or promotions, then please contact the relevant Merchant directly.
There are a number of factors that influence the length of time your data will be retained for, including the purpose for which we use that information and Oxygen8 Group’s obligations under other laws. Oxygen8 Group will retain your data for such a period of time as you remain a customer of Oxygen8 Group, such data is required to complete transactions (including securing future refunds), in order to resolve disputes or as is required to comply with our legal and regulatory obligations (whichever is the longer period). The only exceptions to this are where:
- The law requires us retain your personal information for a longer period, or delete it sooner;
- You exercise your right to have your information erased (where it applies) and Oxygen8 Group does not need to retain it in connection with any of the reasons permitted or required under the law;
- Oxygen8 Group bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those legal proceedings have concluded and no further appeals are possible.
You are entitled to contact us if you require your data to be removed and no longer wish to receive services from Oxygen8 Group. You are also entitled to request the following from Oxygen8 Group, these are called your Data Subject’s Rights, and there is more information on these available from the Information Commissioner’s website: https://ico.org.uk/.
- Right of access –to request access to your personal information and information about how we process it
- Right to rectification –to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
- Right to erasure (also known as the Right to be forgotten) – to have your personal information erased. Please email firstname.lastname@example.org or call us on +44 (0) 808 206 0808.
- Right to restriction of processing – to restrict processing of your personal information
- Right to data portability – to electronically move, copy or transfer your personal information in a standard form
- Right to object – to object to processing of your personal information
- Rights with regards to automated individual decision making, including profiling –rights relating to automated decision making, including profiling
If you have any general questions about your rights or you wish to exercise your rights under the General Data Protection Regulations, please email email@example.com.
SECURITY OF YOUR INFORMATION
We take appropriate technical, procedural and organisational measures to guard against unauthorised or unlawful access to, or processing of, your personal information and against accidental loss or destruction of, or damage to, your personal information. While no computer system is completely secure, we believe the measures implemented by our site and service meet industry standards and reduce the likelihood of security problems to a level appropriate to the type of data involved.
CONTACT AND COMPLAINTS
Please feel free to contact us if you have any questions, comments and requests.
Oxygen8 Group will never seek to extract confidential personal information from you by email (such as account details, passwords etc.). Please do not send confidential information by insecure means. If you receive any suspicious emails or communications that you suspect may be fraudulent please contact us by choosing one of the following options: by calling us on +44 (0) 808 206 0808 or emailing firstname.lastname@example.org.
Should you wish to contact us to discuss a complaint or any concerns about the processing of personal data, please contact our GDPR Team using the following email address: email@example.com.
All complaints will be treated in a confidential manner. If you wish, you are also entitled to raise your concerns directly with the Information Commissioner’s Office. For details on how to contact the ICO, please go to their website
OTHER WEB SITES
Oxygen8 cannot be responsible for the privacy practices of third parties whose web sites may be referenced in the Oxygen8 web site.
This notice is designed to help you understand what cookies are, how Oxygen8 Group uses them and the choices you have with regards to their use.
WHAT ARE COOKIES?
A cookie is a small piece of data sent and stored on a website user’s browser or hard drive or other device when you visit a website. This allows the website to recognise you as a user for either the duration of your visit (session cookie) or for repeat visits (persistent cookie).
Cookies are not harmful and do not contain any personal data like home address, date of birth or credit card information. You can find more information about cookies at:
For a video about cookies visit https://www.google.com/intl/en-GB/policies/technologies/cookies/.
When you access the Oxygen8 Group website or contact Customer Support through our web site, our web server will send a cookie to the device you are accessing the website through. Our Customer Support site uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows us to process your online data and requests.
Session cookies help us make sure you are who you say you are after you have logged in.
Persistent cookies, which only we can read and use, help us to identify the fact that you are a Oxygen8 Group customer or prior site visitor.
CAN I TURN OFF COOKIES?
Yes. You are entitled to disable the cookies used on our website. Users who disable their browser’s ability to accept cookies will be able to browse the Oxygen8 Group website but will not be able to successfully use certain Customer Support features.
It is also possible to configure your browser to reject cookies by modifying the browser settings or preferences. If you wish to do so, we recommend you consult the information provided in the browser or contact the browser vendor for help or instructions.