Privacy Policy - Ovation

 

Privacy Notice

This Privacy Policy explains the practices employed by Ovation in collecting and using information related to the incentive and rewards platforms and associated customer service tools managed by Ovation.

Through contracts with our corporate clients, Ovation's web-based services enable our clients' users to order goods and services for the purposes of business incentive and rewards. To fulfil our obligations to our clients, we will collect and process various types of Personal Data on our users (Data Subjects) through our systems to conduct reward delivery and associated relevant communication, to process order requests and to provide customer support.

All data collected and processed for these purposes is conducted in line with the requirements of the GDPR. The General Data Protection Regulation 2016 replaces the EU Data Protection Directive of 1995 and supersedes the laws of individual Member States that were developed in compliance with the Data Protection Directive 95/46/EC. Its purpose is to protect the "rights and freedoms" of natural persons (i.e. living individuals) and to ensure that personal data is not processed without their knowledge, and, wherever possible, that it is processed with their consent.

Under the EU's General Data Protection Regulation (GDPR) personal data is defined as:

"any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".

Our services are not intended for children and we do not knowingly collect data relating to children.

Who are we?

Ovation Ltd. t/a Ovation Incentives, company number 04222641, (Ovation) is a data processor in respect of personal data provided by our clients.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact: Data Protection Officer

Email address: dpo@ovatioincentives.com

Postal address:

15 Greycoat Place,
London,
SW1P 1SB,
UK

 

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.

The Data We Collect and Process

The personal data we collect will be used solely for the purposed of fulfilling our obligations to our clients in relation to the provision of incentives, rewards and motivation solutions. We do not use, copy, resell, licence your personal data to any third parties for any other reason other than its intended purpose as set out in this privacy notice.

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:

  • Identity Data includes name and username or similar identifier.
  • Contact Data includes address, email address and telephone number.
  • Transaction Data includes details about transactions to and from you.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our web-based services.
  • Profile Data includes your username and password, transaction history, preferences, feedback and survey responses.
  • Usage Data includes information about how you use the services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Third Party Access to Data

We may provide your data to third parties for the legitimate purposes of fulfilling your orders in the normal course of business. Any third party processing your information is also bound by this privacy policy and cannot use, store, or distribute your data for any purpose others than its intended purpose.

Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for Ovation to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

Retention period

Ovation will process personal data for up to 2 years from your last interaction with us and we will store the personal data for this period. Following this period your data will be anonymised and will not be retrievable. Your anonymised data will continue to be used for generating aggregated data and statistics.

Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access- you have the right to request a copy of the information that we hold about you.
  • Right of rectification - you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten - in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing - where certain conditions apply to have a right to restrict the processing.
  • Right of portability - you have the right to have the data we hold about you transferred to another organisation.
  • Right to object - you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling - you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that Ovation refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain.

Any requests will be forwarded on should there be a third party involved in the processing of your personal data.