We are OXGAN and we use, collect and are responsible for certain personal information about you.
When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Data Controller: OXGAN, (company number: SC821441) of 4 Oxgangs Broadway, Edinburgh, EH13 9LQ.
We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
We collect and retain personal information about you (and your personnel) through various means, including: -
We may also obtain personal information from other sources as follows:
Your names, addresses and contact details from other referrers of potential work and/or clients with whom we have relationships.
We may use your personal information to:
In the course of acting for you we routinely share your name, contact details and other information when:
Only where it is relevant to your specific case will such sensitive information be retained on your file. Your file will then require storage and ultimately shredding by our archiving and document destruction contractors in accordance with our data retention guidelines.
For a list of our third party suppliers contact us at purchase@oxgan.co.uk
In rare circumstances some of those third party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see Section 9. “Transfer of your information out of the EEA”.
We will share personal information with law enforcement or other authorities if required by applicable law.
If the provision of personal data is required from you to enable us to provide services we will inform you at the point of collecting information from you, whether you are required to provide the information to us.
6 . How long your personal information will be kept
We will hold your personal information on your file only when necessary or relevant to your matter and/or to our obligations. The period that we are required to retain financial information by applicable UK tax law is currently 6 years.
7. Reasons we can collect and use your personal information
We rely on contract as the lawful basis on which we collect and use your personal data such as name, address, and contact details.
In addition, in respect of information collected to comply with any relevant legislation, such as photo ID, dates of birth and former addresses, we rely on legal obligations.
Our review of the risk of potential harm to you of retaining that personal information is that the risk is small and is outweighed by the benefit to you and to us of being able to recreate the history and documents of the transaction.
In addition, in respect of Special Category data we rely on (i) express consent received from you and/or (ii) our assessment that special category personal information held within the matter file is necessary for the establishment, exercise and or defence of legal rights.
We acknowledge that storage arrangements must be configured and designed to comply with good practice as to the accessibility, security and cyber security of any personal information shared by you.
We may on rare occasions need to share personal information with a recipient located outside the European Economic Area (EEA) (e.g. an advisor or third party engaged by us or you as part of our work).
Countries outside the EEA do not have the same data protection laws as the United Kingdom and EEA. In that situation any transfer of your personal information will be subject to your express consent and we will ensure that we will do so in accordance with European Data Protection Legislation.
If such transfers affect you, then you may contact us to obtain more precise information about those terms, and to obtain copies of relevant documentation.
Our people may occasionally remotely access their email accounts remotely when working abroad (including from jurisdictions outside the EEA). Where they do so they are required to use our systems and access any personal data in accordance with all the usual policies and procedures.
We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
fair processing of information and transparency over how we use your use personal information;
You are entitled to be told by us whether we or someone else on our behalf is processing your personal information;
require us to correct any mistakes in your information which we hold;
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
If you would like to unsubscribe from any marketing emails or Newsletters you can also click on the ‘unsubscribe’ button at the bottom of the email/newsletter. It may take up to 5 working days for this to take place.
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
We hope that we or responsible officer, can resolve any query or concern that you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 02031375221.
This privacy notice was published on 25 July 2018 and was last updated on 24 July 2018.
We may change this privacy notice from time to time. You should check this policy occasionally on our website (www.oxgan.co.uk) to ensure you are aware of the most recent version.
Please contact us or our responsible officer if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us, or our responsible officer please either:
If you would like this notice in another format (for example: audio) please contact us (see ‘How to contact us’ above).
A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website. We use cookies on this website to:
The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your computer or other electronic device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally.
In certain circumstances we may collect personal information about you—but only where you voluntarily provide it (e.g. by completing an online form) or where you purchase goods or services from us.
In most cases we will need your consent in order to use cookies on this website. The exception is where the cookie is essential in order for us to provide you with a service you have requested (e.g. to enable you to put items in your shopping basket and use our check-out process).
There is a notice on our home page which describes how we use cookies and which also provides a link to our website privacy policy. If you use this website after this notification has been displayed to you, we will assume that you consent to our use of cookies for the purposes described in this website cookie policy and our website privacy policy.]
We work with third party suppliers who may also set cookies on our website, for example Facebook, Twitter, Youtube and Bigcommerce. These third party suppliers are responsible for the cookies they set on our site. If you want further information please go to the website for the relevant third party. You will find additional information in the table below.
The table below provides more information about the cookies we use and why:
Name of cookie Owner Purpose for the cookie
Google Analytics This is a web analytics service provided by Google Inc. which uses cookies to show us how visitors found and explored our site and how we can enhance their experience. It provides us with information about the behaviour of our visitors (e.g. how long they stayed on the site and the average number of pages viewed) and also tells us how many visitors we have had.
If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website.
For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies: