ONGOSA

PRIVACY AND COOKIES POLICY

Ongosa ("We", “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the purpose of the General Data Protection Regulation (“GDPR”) and any other national laws or regulations in relation to the protection of personal data that come in force from time to time (collectively the “Data Protection Laws”) the Data Controller is Ongosa Limited.

If you are providing personal information about any other person, you confirm that he/she consents to our use of his/her personal data, and if such person is under 16 you confirm that you have received the consent of his/her guardian or parent and provided a copy of this policy to all parties.

YOUR PERSONAL INFORMATION

Information We Collect From You

We collect and process some or all of the following types of information from you in the course of your use of the website or providing our services:

Mandatory Information

Where you are a user searching for an instructor (“Buyer”), the provision of your name, email address and phone number is required from you to enable Us to contact you and register you as a user of our services. We may also ask you for your age when you make a booking to ensure that we connect you to the correct Professional.

Where you are a Professional, we will also require your company name (if applicable), bank details, [meeting points, Service information, company information] in order to receive payment from you in relation to any commission due to us in relation to the provision of our services.

We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.

Information We Collect From Other Sources

Where you are a Professional, We will also obtain personal data from publically available sources such as social media websites (Tumblr, Facebook, Instagram). However we will only do this with your consent.

USES MADE OF YOUR INFORMATION

Lawful Basis for Processing

We rely on “performance of a contract” as the lawful basis on which We collect and process your personal data in order to fulfil our contractual obligations when you register to use our services, and/or contact us in relation to the services you have registered to use.

We also rely on “performance of a contract” when sharing your personal data as part of providing our services. Where you are a Buyer, we will share your personal information with relevant Professionals that suit the criteria in your search, and with any payment processor we use when you complete a booking. Where you are a Professional, we will share your personal information with Buyers seeking to book services in order for them to correspond with you.

We rely on your consent to use, collect and share your personal data in relation to any surveys you participate to. Where you are a Professional, we rely on your consent to collect, use and share any personal data we obtain from social media websites in order to populate and promote your profile on our Website.

We rely on “legitimate interest” as the lawful basis on which we collect and process your personal data in order to:

Purposes of Processing

We use information held about you in the following ways:

Marketing

In addition to the above uses, We may use your information, to notify you about goods or services which may be of interest to you by electronic means (e-mail or SMS). Where you have contacted us and made a general enquiry, we will do so only where we have received your consent. Where you are an existing Buyer and Professional, we will rely on our “legitimate interest” in promoting our services to you.

If you do not want Us to use your data in this way please either (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform Us at any time by contacting Us at the contact details set out below.

DISCLOSURE OF YOUR INFORMATION

We routinely disclose your personal data to third parties as follows:

We may also disclose your personal data to third parties:

Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.

STORING YOUR PERSONAL DATA

Security

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We process payment transactions, these will be encrypted using SSL technology. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

Keeping your Personal Data up to Date

If your personal details change you may update them by accessing your account on the Website, or by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.

We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.

How Long We Keep your Personal Data

We will hold the data set out above for a reasonable time having regard to the nature of the personal data and the purpose for which it was collected.  In particular:

Where We Store your Personal Data

All information We hold about you is stored on our supplier’s secure servers.

The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.

Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to a written agreement with the relevant service ensuring an adequate level of protection that we will have reviewed, approved and/or negotiated. If you would like further information please contact Us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

YOUR RIGHTS

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to: - access to your personal data and to certain other supplementary information that this Policy is already designed to address - require Us to correct any mistakes in your information which We hold - require the erasure of personal data concerning you in certain situations - receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations - object at any time to processing of personal data concerning you for direct marketing - object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you - object in certain other situations to our continued processing of your personal data - otherwise restrict our processing of your personal data in certain circumstances - claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please: - email, call or write to Us. - let Us have enough information to identify you, - let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and - let Us know the information to which your request relates.

HOW TO COMPLAIN

We hope that We can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Policy at any time. Any changes We may make to our Policy in the future will be notified and made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied privacy policy.

INFORMATION ABOUT OUR USE OF COOKIES

We may collect information about your visit to our Website for systems administration purposes. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services, and understand how you found our Website.

Our Website uses cookies to distinguish you from other users of our Website. This helps Us to provide you with a good experience when you browse our Website and also allows Us to improve the Website. By using our Website you agree to our use of cookies as more specifically set out below.

A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

The cookies We use include:

Please note that third parties affiliates may also use cookies, over which We have no control.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website.

Google Analytics

            Our website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). The information generated by the cookie about your use of our website will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.  Further information about Google’s privacy policy may be obtained from http://www.google.com/privacy.html.