Privacy Policy

Introduction

This Privacy Policy explains how OpenAgain protects the privacy of your personal information. We are firmly committed to protecting the privacy and confidentiality of personal information and maintain robust physical, electronic and procedural safeguards to protect personal information in our care.

This ("Website" and “System”) www.openagain.co.uk is owned and operated by Open Again Limited, a limited company registered in England under company number 12706504, with registered office at 27 Old Gloucester Street, London, WC1N 3AX.

We appreciate your interest in this Website or use of the System and we are committed to protecting and respecting your Privacy. This Privacy Policy (which forms part of our Disclaimer) details how your data is collected and used by OpenAgain or its clients. For the purposes of the Data Protection Act (“Act”), OpenAgain is the Data Controller of our own information captured and also the Data Processor on behalf of our clients using the System.

Definitions

We use a number of different terms in this policy. To make sure it is clear what we are talking about, here are some definitions of what we mean by each of these terms:

Personal Data

Personal Data means data about a living individual who can be identified from those data. This includes information such as a name, address, telephone number, email address, or other account number, and information about that individual’s activities when directly linked to that person such as information about his or her use of the OpenAgain website or system. Personal information can also include demographic information such as date of birth, gender, geographic area and preferences when such information is linked to other personal information that identifies you. Personal information does not include “aggregate” information, which is data we collect about a group or category of products, services or people, from which individual identities have been removed.

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on a User’s device.

Data Controller

Data Controller means a person or entity who determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of the data you give us to enquire, setup and manage your OpenAgain System.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means a person or entity who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject

Data Subject is any living individual who is the subject of Personal Data.

User

The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

The Type of Data we Collect

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally, identifiable information may include, but is not limited to: Email address, Name, Address, County, Postal code, Credit Card details, Cookies and Usage Data.

We may use your Personal Data to contact you with information about new features or announcements, to update you on the status of your account, to issue invoices, receipts or payment reminders, other information that may be relevant to you.

We don’t recommend it, but you can opt out of receiving communication about new features and similar announcements by clicking on the ‘opt-out’ link or instructions in the email. You cannot opt out of receiving transactional emails or notifications relating to your account status, security announcements or other communication that might be essential to the operation of your account.

Of course, if you are no longer a user of the OpenAgain System, and all business with us is concluded (for example you closed your business and your OpenAgain account) you can opt out of all communications from us.

Usage Data

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

Cookies are small pieces of data stored on a User’s device.

We use cookies and similar tracking technologies to track the activity on our Website and System and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you will not be able to use some or all of our Service.

Examples of Cookies we use: session cookies (we use these cookies to operate our Service) and preference cookies (we use these cookies to remember your preferences and various settings).

How we use Personal Information

We collect and use your personal information to support the NHS in their ‘track & trace’ initiative to communicate with individuals with regards to the Covid-19 pandemic.

We also collect and use your personal information to operate our website and deliver our services to you and your customers. We will use your personal information to provide you with customer management utilities, technical support, product upgrades and information. We also use your personal information to monitor the usage of the service, and to detect, prevent and address technical issues.

Your personal data will only be used for other purposes if you have given permission for us to do so.

Your Privacy and Disclosure of Data

We will not disclose any material uploaded to our servers to anyone else without your permission, unless as permitted or required by law; to various regulatory bodies and law enforcement officials and agencies to protect against fraud and for related security purposes.

If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Retention of Data

We will only keep your information for as long as it is necessary, taking into account of Government advice and the on-going risk presented by Coronavirus. Currently personal data will only be kept for 21 days unless consent is given to retain for longer periods.

Health information provided by you in relation to this outbreak of Coronavirus will not be used for any other purpose.

When the personal data is no longer needed for this purpose, it will be securely deleted. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or to determine business intelligence or we are legally obligated to retain this data for longer time periods.

Security of Data

OpenAgain has an extensive range of security features in place to protect your personal information from unauthorised access. In addition, we maintain our servers in a controlled and secured physical environment, however no method of data storage and transmission (whether electronic or physical) can be deemed to be 100% secure and therefore we cannot make this guarantee.

You have an important role in keeping your data secure. You are responsible for maintaining the confidentiality of your personal details, account details and password. Your passwords protect your personal information and you are responsible for any activities that occur in your account or in respect of your use of this service. Please let us know immediately if you suspect the security of your password or account has been compromised in any manner.

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

The General Data Protection Regulation requires specific conditions to be met to ensure that the processing of personal data is lawful. These relevant conditions are below:

  • Article 6(1)(d) – is necessary in order to protect the vital interests of the data subject or another natural person.

 Recital 46 adds that “some processing may serve both important grounds of public interest and the vital interests of the data subject as for instance when processing is necessary for humanitarian purposes, including for monitoring epidemics and their spread”.


  • Article 6(1)(e) – is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. 

Section 8(c) of the Data Protection Act sets out that such a task must be necessary for the performance of a function conferred on a person by an enactment or rule of law.

The processing of special categories of personal data, which includes data concerning a person’s health, are prohibited unless specific further conditions can be met. These further relevant conditions are below:

  • Article 9(2)(i) – is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health.

Schedule 1, Part 2(6) – is necessary for reasons of substantial public interest and for the purpose of a function conferred on a person by an enactment or rule of law; eg Health Protection (Coronavirus) Regulations 2020 and Coronavirus Act 2020

Schedule 1, Part 1(3) – is necessary for reasons of public interest in the area of public health, and is carried out by or under the responsibility of a health professional, or by another person who in the circumstances owes a duty of confidentiality under an enactment or rule of law, eg Governmental guidance published by Public Health England

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We also extend these rights to all users, even if you are located outside of the EEA. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where OpenAgain relied on your consent to process your personal information.



These rights can be enacted by contacting us on [email protected] Please note that we may ask you to verify your identity before responding to such requests. (If you are a customer of a business that uses the OpenAgain system you will need to contact that business directly to discuss or evoke your protection rights.)



If you live in the EEA you have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

OpenAgain as a Data Processor (GDPR)

We provide internet-based software typically used to manage online data collection, processing ordering-based businesses. If you are a business using the OpenAgain System, you are likely to store personal information about your staff and/or customers in your OpenAgain account. According to the GDPR, in these circumstances you are considered to be the Data Controller, and we are your Data Processor.

You are responsible for making sure that your Customers’ privacy and associated rights are respected. As your Data Processor we will take care to protect the privacy of your customers and will process their Personal Data in accordance with the terms of our agreement with you, and under your lawful instruction.

Third Party Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms here.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Policy Changes

From time to time, we may review and update this Privacy Policy. Revised versions will be updated on this website and will be effective once posted. Your continued use of the Website and System will be deemed as acceptance of the policy.

Feedback

We welcome your feedback. If you have any comments about this Privacy Policy or would like to contact us or our Data Protection Officer for any reason, please email [email protected].

© 2020 Open Again Limited. All rights reserved.

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