Blue Owl Network Ltd the company behind the AutoConvert platform understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.autoconvert.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
"Account" means an account required to access and/or use certain areas and features of Our Site;
"Cookie" means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
"Cookie Law" means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
"Personal Data" means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. As defined in the General Data Protection Regulation 2016 (GDPR);
"We/Us/Our" means Blue Owl Network Ltd, a limited company registered in England under 09633716, whose registered address is The Granary, 50 Barton Road, Worsley, Greater Manchester, M28 2EB.
2. Information About Us
2.1 Our Site is owned and operated by Blue Owl Network Ltd, a limited company registered in England and Wales under company number 09633716, whose registered address is The Granary, 50 Barton Road, Worsley, Greater Manchester, M28 2EB.
2.2 Our VAT number is GB228856472.
2.3 Our Data Protection Officer is Martin Nolan, and can be contacted by email at firstname.lastname@example.org, by telephone on 0161 850 7330, or by post at The Granary, 50 Barton Road, Worsley, Greater Manchester, M28 2EB.
2.4 We are regulated by Information Commissioner's Office and registered with the Information Commissioner's Office (ICO) in compliance with the Data Protection Act of 1998 (the Act). Our registration number is ZA139733. You can review general information on how we process your information on the ICO's public register but this statement provides specific details.
2.5 We are a member of the Consumer Finance Association (http://cfa-uk.co.uk/)
3. Scope - What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 Information – Be informed about how we use your personal data;
4.1.2 Access – Obtain access to your personal data that we hold;
4.1.3 Rectification – Request that your personal data is corrected if you believe it is incorrect or incomplete;
Erasure – Request that we erase your personal data in the following circumstances:
(a) If we are continuing to process personal data beyond the period when it is necessary to do so for the purpose for which it was originally collected;
(b) If we are relying on consent as the legal basis for processing and you withdraw consent;
(c) If we are relying on legitimate interest as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing;
(d) If the personal data has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation); or
(e) If it is necessary to delete the personal data to comply with a legal obligation.
Restriction – Ask us to restrict our data processing activities where you consider that:
(a) Personal data is inaccurate;
(b) Our processing of your personal data is unlawful;
(c) Where we no longer need the personal data, but you require us to keep it to enable you to establish, exercise or defend a legal claim; or
(d) Where you have raised an objection to our use of your personal data.
4.1.6 Portability – Request a copy of certain personal data that you have provided to us in a commonly used electronic format. This right relates to personal data that you have provided to us that we need in order to perform our agreement with you and personal data where we are relying on consent to process your personal data.
4.1.7 Objection – Object to our processing of your personal data where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection, we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal data.
4.1.8 Automated decisions – Not be subject to automated decisions which produce legal effects, or which could have a similarly significant effect on you. (i) As part of the processing of your personal data, decisions may be made by automated processes. This means we may automatically decide that you pose a fraud or money laundering risk if:; (ii) our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers; or is inconsistent with your previous submissions; or (iii) you appear to have deliberately hidden your true identity.
If you would like to exercise any of your rights or find out more, please contact us our data protection officer on the contact details provided above.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary and only for the purposes for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails or consenting for your data to be processed), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Site;
6.2.3 Personalising and tailoring your experience on Our Site;
6.2.4 Supplying Our products and/or services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Personalising and tailoring Our products and/or services to you;
6.2.6 Replying to emails from you;
6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by using the links on the marketing emails or, if you’d prefer, by contacting us;
6.2.8 Market research;
6.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone and/or text message and/or post with information, news and offers on Our products and/or services, you can opt-out at any time. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 or ePrivacy regulation (when it comes into force).
6.4 Third parties whose content or services which appear or are used by Us on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.6 We do not keep your personal data for any longer than is necessary and only for the purposes for which it was first collected.
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Some or all of your data may be stored outside of the European Economic Area ("the EEA") (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, then the Privacy Shield register will be checked to ensure that your data is treated as safely and securely as it would be within the UK and under GDPR.
7.2.1 For emails from Us, your data will be processed in our Sparkpost repository, which as a result will mean your information may be transferred to a third country. We can confirm the existence of a relevant adequacy agreement is in place with Sparkpost and Sparkposts’ certification under the EU-U.S. and Swiss-U.S. Privacy Shield covers all email communications and platforms they have in use. This meets the requirements of data transfer to a third country under the Data Protection act 2018 and also the General Data Protection Regulation.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
8. Do We Share Your Data
8.1 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.2 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.3 We may sometimes use third party data processors that are located outside of the European Economic Area ("the EEA") (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information
You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge and within 30 days. Please contact Us for more details at email@example.com, or using the contact details on the website.
13.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for analytics, site usage issues, authentication & consent. For more details, please refer to section 6, above, and to section 13.6 below.
13.3 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
13.4 Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
13.5 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.10, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
13.6 The following first party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|requestverificationtoken||A session cookie used for authentication to the Platform||Yes*|
|asp.net_sessionid||A session cookie used for authentication to the Platform||Yes*|
|sandhurstcrmauth||A persistent cookie used for authentication to the Platform||Yes*|
|UIConfiguration||A session cookie logged in users may use if they choose to customise the account||No|
* to login into the platform
and the following third party Cookies may be placed on your computer or device:
|Name of Cookie||Provider||Purpose|
|Google Analytics||Records website usage statistics which allows us to improve the website for you. All data is anonymized.|
|GetClicky||Roxr Software, Ltd||Records website usage statistics which allows us to improve the website for you. All data is anonymized.|
|Tawk**||tawk.to inc.||tawk uses a number of cookies for a live chat application used to provide live support for logged in users of AutoConvert.|
** Represents all cookies from same companies
13.7 Our Site uses analytics services provided by Google and Inspectlet. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and/or services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
13.8 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
13.9 The analytics service(s) used by Our Site use(s) the following Cookies:
|Name of Cookie||First / Third Party||Provider||Purpose|
|Google Analytics||3rd||Google Analytics||Records website usage statistics which allows us to improve the website for you. All data is anonymized.|
13.10 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
13.11 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
13.12 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
14. Contacting Us