Octagon Privacy Policy

Welcome to the Octagon Group privacy notice.

 

Octagon Developments Limited and its group of companies (“Octagon”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

Purpose of this privacy notice

 

This privacy gives you information on how Octagon collects and processes your personal data through your use of this website, including any data you may provide through this website when you contact us through our form.

 

This website is not intended for children and we do not knowingly collect data relating to children.

 

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions (including in our terms of business) when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

 

Controller

 

Octagon is the controller and responsible for your personal data (collectively referred to as, “we”, “us” or “our” in this privacy notice).

 

Contact details

 

If you have any questions relating to our use of your data, please contact us as follows:

 

Octagon Developments Ltd., Weir House, Hurst Road, East Molesey, Surrey KT8 9AY

 

​Website : https://www.octagon.co.uk

Email: administrator@octagon.co.uk

​Call: 020 8481 7500

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

Third-party links

 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy or notices of every website you visit.

 

1. Your personal data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

 

If you fail to provide personal data

 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

 

Technical Data from analytics providers such as Google based within or outside the EU;

Identity Data where an employee of ours gives your contact details as an emergency contact or a referee.

 

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

Generally, we do not rely on consent as a legal basis for processing your personal data.

 

Purposes for which we will use your personal data

 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest 
To register you as our customer Identity

Contact

Performance of a contract with you
To carry out services including:

(a) management of payments, fees and          charges;

(b) to collect and recover money owed to us

Identity

Contact

Financial

Transaction

Communications

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you such as notifying you of changes to our terms and privacy notice

 

 

Identity

Contact

Profile

Communications

Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Identity

Contact

Technical

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Technical

Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

3. Marketing

We strive to provide choices regarding certain personal data uses, particularly around marketing.

We may provide marketing communications where an individual signs up for such communications and, in each case, has not opted out of receiving that marketing.

4. Opting Out

An individual can ask us to stop sending marketing messages at any time by following the opt-out links on any marketing message sent to them or by contacting us at any time. If at any time you would like to unsubscribe from receiving future emails, you can email us at enquiries@octagon.co.uk.

5. Cookies

Browsers can be set to refuse all or some browser cookies, or to provide an alert when websites set or access cookies. If cookies are disabled or refused, some parts of our website may become inaccessible or not function properly.   A cookie is an element of data that a website can send to a browser which may then be stored on that system. It does not contain confidential information such as home addresses, telephone numbers or credit card details. Users can set preferences for how Google advertises to you using the Google Ad Settings page.

6. Change of Purpose

7. Disclosures of Personal Data

8. International Transfers

9. Data Security

10. Data Retention

11. Data Subjects’ Legal Rights

11.1 Under certain circumstances, a data subject has rights under data protection laws in relation to their personal data including:

11.2 To exercise any of the rights listed above, please ensure that requests are emailed to administrator@octagon.co.uk

11.3 No fee usually required

A data subject will not have to pay a fee to access their personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if we receive a request which is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with such a request in these circumstances.

11.4 What we may need

We may need to request specific information from a data subject exercising their rights to help us confirm their identity and ensure their right to access their personal data (or to exercise any of their other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact the requesting data subject to ask for further information in relation to their request to speed up our response.

11.5 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if a request is particularly complex or there are a number of requests. In this case, we will notify the data subject and keep them updated.

GLOSSARY

12 Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give our clients the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on data subjects (both positive and negative) and their rights before we process their personal data for our legitimate interests. We do not use personal data for activities where our interests are overridden by the impact on a data subject (unless we have their consent or are otherwise required or permitted to by law). Further information about how we assess our legitimate interests against any potential impact on data subjects in respect of specific activities can be obtained by contacting us.

Performance of Contract means processing the personal data where it is necessary for the performance of a contract or any necessary steps prior to entry into such contract.

Comply with a legal or regulatory obligation means processing personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

13. Third Parties

External Third Parties

13.1 Our clients for whom we are providing services.

13.2 Our consultants who act as subcontractors for some of our services.

13.3 Service providers acting as processors based inside EEA who provide IT and system administration services.

13.4 Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

13.5 HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom.

 

Data Subject Legal Rights

13.6 Data subjects have the right to:

13.6.1  Request access to their personal data (commonly known as a “data subject access request”). This enables them to receive a copy of the personal data we hold about them and to check that we are lawfully processing it.

13.6.2  Request correction of the personal data that we hold about them. This enables a data subject to have any incomplete or inaccurate data we hold about them corrected, though we may need to verify the accuracy of the new data the data subject provides to us.

13.6.3  Request erasure of their personal data. This enables a data subject to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Data subjects also have the right to ask us to delete or remove their personal data where they have successfully exercised their right to object to processing (see below), where we may have processed their information unlawfully or where we are required to erase their personal data to comply with law. Note, however, that we may not always be able to comply with a request of erasure for specific legal reasons which will be notified to a data subject where relevant, if applicable, at the time of their request.

13.6.4  Object to processing of their personal data where we are relying on a legitimate interest (or those of a third party) and there is something about a data subject’s particular situation which makes them want to object to processing on this ground as it impacts on their fundamental rights and freedoms. They also have the right to object where we are processing their personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process information which override such rights and freedoms.

13.6.5  Request restriction of processing of their personal data. This enables them to ask us to suspend the processing of their personal data in the following scenarios: (a) if they want us to establish the data’s accuracy; (b) where our use of the data is unlawful but they do not want us to erase it; (c) where they need us to hold the data even if we no longer require it as they need it to establish, exercise or defend legal claims; or (d) they have objected to our use of their data but we need to verify whether we have overriding legitimate grounds to use it.

13.6.6  Request the transfer of their personal data to them or to a third party. We will provide to them, or a third party they have chosen, their personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which a data subject initially provided consent for us to use or where we used the information to perform a contract with them.

13.6.7  Withdraw consent at any time where we are relying on consent to process personal data. However, this will not affect the lawfulness of any processing carried out before consent is withdrawn.

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