OYSTEO LIMITED DATA PROTECTION AND PRIVACY POLICY


Last updated: February 2023



DEFINITIONS

  • OYSTEO: OYSTEO means Oysteo Limited, its subsidiaries and associates. Oysteo Limited is a company organised under the law of England & Wales, Registered Number 12523542, and whose registered office is at 64-66 Redchurch Street, London E2 7DP.
  • GDPR: General Data Protection Regulation Act.
  • Data Controller: Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
  • Data Processor: Data Processor means any natural or legal person who processes the data on behalf of the Data Controller.
  • Data Subject: Data Subject is any living individual who is using our Service and is the subject of Personal Data.

1. INTRODUCTION

This Global Privacy & Data Protection Policy (“Policy”) describes OYSTEO’s global practices to ensure an adequate protection of personal data (i.e., any information relating to an identified or identifiable natural person), for all data processing carried out in the framework of its business and activities (“Personal Data”)


This Policy is intended to apply to all processing activities OYSTEO conducts towards the persons it deals with in its professional business activities.


Specific privacy and data protection information notices (“Privacy Notice”) and/or consent forms will, if necessary, be communicated to you regarding specific situations where OYSTEO may process your Personal Data. These Privacy Notices shall describe in more detail how your Personal Data will be processed in relation with the processing in question. If the legislation of your country so requires, this Policy and/or Privacy Notices may be supplemented by local mandatory provisions


This Policy may be modified by OYSTEO from time to time, in particular to adapt its terms to evolutions or changes of applicable legislations and/or to OYSTEO’s practices. Changes will be available on this page. We invite you to check this Policy periodically. Historic versions are available on request from the Company.**



2. PRINCIPLES FOR PROCESSING PERSONAL DATA

Our principles for processing personal data are:

  • Fairness and lawfulness. When we process personal data, the individual rights of the Data Subjects must be protected. All personal data must be collected and processed in a legal and fair manner.
  • Restricted to a specific purpose. The personal data of Data Subject must be processed only for specific purposes.
  • Transparency. The Data Subject must be informed of how his/her data is being collected, processed, and used.


3. WHAT PERSONAL DATA WE COLLECT AND PROCESS

OYSTEO collects, or you may provide to us, several types of information from and about users of our website and social media channels, including information:

  • by which you may be personally identified, such as name, postal address, e-mail address, telephone number, and other identifying information;
  • that is about you but individually does not directly identify you, such as date of birth; and
  • about your internet connection, the equipment you use to access our Website and usage details, such as Internet Protocol (IP) address.

We collect this information directly from you when you provide it to us, automatically as you navigate through the site and from third parties, for example, our business partners.


We also may use online technologies to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking), which may include the use of cookies (data files placed on the hard drive of your computer that may be necessary for you to access our website), web beacons (electronic files that allow OYSTEO to collect aggregated information on users visiting our Website), and Google or Two types of cookies are used on this website - session cookies, which are temporary cookies that remain in the cookie file of your browser until you leave the site, and persistent cookies, which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).


Cookies will typically contain the name of the domain from which the cookie has come, the "lifetime" of the cookie, and a value, usually a randomly generated unique number.


Cookies allow us to obtain information regarding users of our site which essentially helps us to provide you with a better user experience and tailor our services to your individual needs. We may collect information such as your IP address, online activity, web browser details and online activity. We will not however collect or store any of your passwords or other highly sensitive data. You can adjust your settings on oysteo.com


We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services or any other e-commerce facility.
  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

In some regions, countries, or U.S. states (such as California), you may have the right to opt out of such tracking. Please see the sections below, “Your Rights” and “Contact Us,” if you wish to exercise such rights. To opt out of the use of Google Analytics, you may visit the following link: https://tools.google.com/dlpage/gaoptout/. To opt out of interest-based advertising through the Network Advertising Initiative (NAI), please visit http://optout.networkadvertising.org/?c=1



4. HOW WE USE THE PERSONAL DATA

OYSTEO uses the collected personal data for various purposes:

  • to carry out our business operations; carry out marketing and sales; respond to your requests; to keep track of our interactions and meetings, such as when you contact us for information and support.
  • to comply with legal or regulatory obligations that apply to OYSTEO; monitor safety; manage adverse events; carry out prevention and investigatory activities; carry out administrative formalities, registration, declarations, or audits.
  • to conduct research and development; carry out market research and other operations; analyse demographic data; offer special programs, activities, trials, events, or promotions via our services; carry out market or consumer studies.
  • to provide you access to online services, application and platforms; manage your online accounts.
  • to allow us to identify or authenticate you; provide or verify your credentials including via passwords, password hints, security information and questions, government-issued ID, social handles, professional accreditation, driver’s license data, and passport data.
  • to improve and develop our products and services; identify usage trends and develop new products and services; understand how you and your device interacts with our services; track and respond to safety concerns; determine the effectiveness of our promotional campaigns, conduct surveys.
  • to personalize your experience when using our services; ensure that our services are presented in the way that best suits you; understand your professional and personal interests in our content, products and services or other content and adapt our content to your needs and preferences; present you products and offers tailored to you.
  • to allow us to communicate with you; respond to your requests or inquiries; provide support for products and services; provide you with important information, administrative information, required notices, and promotional materials; send you news and information about our products, our services, our brands, our operations; organize and manage professional events and congresses, including your participation to such events.
  • to process payments we may need to issue in a specific situation; verify your financial data to facilitate further payments.
  • to respond to legal requests from administrative or judicial authorities, in accordance with applicable laws; comply with a Court Order, subpoena, required registration, or legal process
  • to protect our rights and interests; protect the health, safety, and security of OYSTEO personnel and premises; carry out internal audits, asset management, system and other business controls; manage business administration (finance and accounting, fraud monitoring and prevention); maintain the security of our services and operations; protect our rights, privacy, safety or property, to allow us to pursue available remedies or limit the damages that we may incur as necessary; to protect ourselves against possible fraudulent actions.

OYSTEO may collect your Personal Data from different sources:

  • Data that you communicate to us through various media, through registrations, applications surveys, or direct and indirect interactions with OYSTEO. For example, data you provide to register to events sponsored by OYSTEO, to submit an online application, to send us a request for information, etc.
  • Data that we collect automatically, for instance when following your interactions with our websites, platforms, applications, and services through certain technologies, such as cookies.
  • Data that we collect in accordance with applicable law from public sources available, including data that is published by you in all forums and media.
  • Data that we obtain legally from third parties, for example, when we may need to confirm contact or financial information or to verify licenses of professionals. In such case, we generally receive such Personal Data from third parties that are authorised to do so in the framework of their own privacy and data protection policies or in accordance with the law. As applicable, we will inform you in the Privacy Notice of the identity of those third parties and will invite you to refer to their privacy and data protection policies to inquire on the origin of such Personal Data and the condition of their collection.

OYSTEO’s legal basis for collecting and using the personal data described in this Data Protection Policy depends on the personal data we collect and the specific context in which we collect the information:

  • OYSTEO needs to perform a contract with you
  • You have given OYSTEO permission to do so
  • Processing your personal data is in OYSTEO’s legitimate interests
  • OYSTEO needs to comply with the law

OYSTEO is a multinational organization with affiliates, partners and subcontractors located in many countries around the world. For that reason, OYSTEO may need to transfer (via access, visualization, and storage) your Personal Data in other jurisdictions, including from the European Economic Area to outside the European Economic Area, in countries which may not be regarded as providing the same level of protection as the jurisdiction you are based in. In cases where OYSTEO needs to transfer Personal Data outside the European Union, it shall ensure that adequate safeguards, as required under applicable data protection legislation, will be implemented (including, notably, the European Commission’s Standard Contractual Clauses, as applicable).



6. RETENTION OF PERSONAL DATA

OYSTEO will retain your personal information only for as long as is necessary for the purposes set out in this Data Protection Policy. OYSTEO will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.



7. DATA PROTECTION RIGHTS

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. 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:

  • to have access upon simple request to your Personal Data – in which case you may receive a copy of such data (if requested), unless such data is made directly available to you, for instance within your personal account.
  • to obtain a rectification of your Personal Data should your Personal Data be inaccurate, incomplete or obsolete.
  • to obtain the deletion of your Personal Data in the situations set forth by applicable data protection law (‘right to be forgotten’).
  • to withdraw your consent to the data processing without affecting the lawfulness of processing, where your Personal Data has been collected and processed on the basis of your consent.
  • to object to the processing of your Personal Data, where your Personal Data has been collected and processed on the basis of legitimate interests of OYSTEO, in which case you will need to justify your request by explaining to us your particular situation.
  • to request a limitation of the data processing in the situations set forth by applicable law;
  • to receive your Personal Data for transmission from OYSTEO to a third-party or to have your Personal Data directly transferred by OYSTEO to the third-party of your choice, where technically feasible (data portability right allowed only where the processing is based on your consent)

If you would like to exercise any of these rights, please contact us as described in the “How to Contact Us” action below and we will take necessary steps to respond as soon as possible. You may also file a complaint before a competent data protection authority regarding the processing of your Personal Data. While we suggest that you contact us beforehand, if you wish to exercise this right, you should contact directly the competent data protection authority.


8. HOW TO CONTACT US

You can send any request pertaining to OYSTEO’s use of your Personal Data by submitting an email to [email protected] or writing to the Company, addressing your letter to the Data Controller. OYSTEO’s appointed Data Controller is Catherine Macdonald, Oysteo Limited, Unit 4.01, The Tea Building, 56 Shoreditch Hight Street, London E1 6JJ.



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