Privacy policy

This privacy policy applies between you, the User of this Website and Openforwards Ltd, the owner and provider of this Website. Openforwards Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

2. In this privacy policy, unless the context requires a different interpretation:
   1. the singular includes the plural and vice versa;
   2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
   3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
   4. “including” is understood to mean “including without limitation”;
   5. reference to any statutory provision includes any modification or amendment of it;
   6. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of Openforwards Ltd and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

This Application collects some Personal Data from its Users.

Owner and Data Controller

Jim Lucas, Openforwards Ltd.

The Jewellery Business Centre, Suite 410, 95 Spencer Street, Birmingham, UK. B18 6DA

Owner contact email: support@openforwards.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage data and email address.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

The Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
All Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory. Users are free not to communicate this Data without any consequences on the availability or the functioning of the service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

Place

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

The use of the collected Data

The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Analytics, Displaying content from external platforms, Interaction with external social networks and platforms, Remarketing and behavioural targeting, SPAM protection, Managing contacts and sending messages and Interaction with live chat platforms.

The Personal Data used for each purpose is outlined in the specific sections of this document.

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Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilises the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services

Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy – Opt Out

Facebook Ads conversion tracking (Facebook, Inc.)

Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Application.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

Displaying content from external platforms

This type of services allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Contacting the User

Contact form (this Application)

By filling in the contact form with their Data, the User authorises this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: email address, first name and last name.

Google Maps widget (Google Inc.)

Google Maps is a maps visualisation service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

Interaction with external social networks and platforms

This type of services allows interaction with social networks or other external platforms directly from the pages of this Application.
The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

LinkedIn button and social widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

Facebook Like button and social widgets (Facebook, Inc.)

The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

Twitter Tweet button and social widgets (Twitter, Inc.)

The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

Typeform (Typform SL.)

Typeform creates conversational online forms and collects data from respondents.

Personal Data collected:  Survey responses

Place of processing: Spain – Privacy Policy

Interaction with live chat platforms

This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Application, for contacting and being contacted by this Application support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

Managing contacts and sending messages

This type of services makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

ConvertKit (ConvertKit LLC.)

ConverKit is an email address management and message sending service provided by ConvertKit LLC.

Personal Data collected: email address.

Place of processing: US – Privacy Policy

Remarketing and behavioural targeting

This type of service allows this Application and its partners to inform, optimise and serve advertising based on past use of this Application by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioural targeting activity.
In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

AdWords Remarketing (Google Inc.)

AdWords Remarketing is a remarketing and behavioural targeting service provided by Google Inc. that connects the activity of this Application with the Adwords advertising network and the Doubleclick Cookie.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy – Opt Out

SPAM protection

This type of services analyses the traffic of this Application, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.

Akismet (Automattic Inc.)

Akismet is a SPAM protection service provided by Automattic Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy

Google reCAPTCHA (Google Inc.)

Google reCAPTCHA is a SPAM protection service provided by Google Inc.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

Cookie Policy

This Application uses Cookies. 

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services.

The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

This Application does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Information about this privacy policy

The Data Controller is responsible for this privacy policy.

Definitions and legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Application, which must coincide with or be authorised by the Data Subject, to whom the Personal Data refers.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organisation authorised by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organisation with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The hardware or software tool by which the Personal Data of the User is collected.

Cookies

Small piece of data stored in the User’s device.

This privacy policy relates solely to this Application.

Changes of business ownership and control

13. Openforwards Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Openforwards Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
14. We may also disclose Data to a prospective purchaser of our business or any part of it.
15. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Functionality of the Website

19. To use all features and functions available on the Website, you may be required to submit certain Data.
20. You may restrict your internet browser’s use of Cookies. For more information see the clause below (Cookies).

Security

22. Data security is of great importance to Openforwards Ltd and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
23. If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.
24. We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.

General

35. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
36. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
37. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
38. This privacy policy is governed by and interpreted according to English law. All disputes arising under this privacy policy are subject to the exclusive jurisdiction of the English courts.

Changes to this privacy policy

39. Openforwards Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.You may contact Openforwards Ltd by email at support@openforwards.com. 9th May 2018