Privacy Policy

OPPLY DATA PROTECTION & PRIVACY POLICY

BACKGROUND:

Opply Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website and all related websites and domains which we operate (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested when you access Our Site or use our Services. 

1. Definitions and Interpretation 

In this Policy the following terms shall have the following meanings:  

1. Information About Us     

Our Site is owned and operated by Opply Ltd, a limited company, registered in England under company number 13555177. Registered address: 7 Bell Yard, London, England, WC2A 2JR

1. What Does This Policy Cover?

This Privacy Policy applies to your use of Our Site and Services. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

1. What Is Personal Data?
   1. Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
   2. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
2. What Are My Rights?
   1. Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
      1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us.
      2. The right to access your personal data 
      3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
      4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold, unless we have legitimate reasons for continuing to hold it. 
      5. The right to restrict (i.e. prevent) the processing of your personal data.
      6. The right to object to us using your personal data for a particular purpose or purposes.
      7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
      8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
      9. Rights relating to automated decision-making and profiling.
   2. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
   3. It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
   4. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves however, so please contact us first.
3. What Data Do You Collect and How?

We collect and store the data you provide to us when you use Our Site, including registration details and messages which you transmit by means of Our Site, including chat messages.  We also collect and store data relating to relevant product suppliers, which is obtained from publicly available sources.

1. How Do You Use My Personal Data?
   1. Under the Data Protection Legislation, we must always have a lawful basis for using personal data. Where we collect data from you, the lawful basis will normally be your consent to the processing of your data in the manner explained to you.  You express your consent by providing us with your information, e.g. on registration.  In other cases the lawful basis will be the need to process personal data for the purposes of our legitimate interest in providing our Services.
   2. With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
   3. Our Site may use third-party Cookies, as described below. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties if you give your consent to the deployment of third-party Cookies.
   4. We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.
   5. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
   6. In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
2. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. 

1. How and Where Do You Store or Transfer My Personal Data?

We may store some or all of your personal data in countries outside of the UK and EEA. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

1. We will only store or transfer personal data in or to third countries where (1) adequate safeguards for the transfer are implemented in accordance with the Data Protection Legislation, or (2) the legal system of the third country is deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.
2. The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
   1. implementing technical security measures designed to protect your data against loss or theft;
   2. limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and
   3. implementing procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

1. Do You Share My Personal Data?
   1. We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions..
   2. If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
   3. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
   4. If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
   5. If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation
2.  How Can I Control My Personal Data?
   1. In addition to your rights under the Data Protection Legislation, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).
   2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
3. Can I Withhold Information?
   1. You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
   2. You may restrict our use of Cookies as described below. 
4. How Can I Access My Personal Data?
   1. If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
   2. All subject access requests should be made in writing and sent to the email or postal addresses referred to in Part 15 below. 
   3. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
   4. We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request.
5. How do you use Cookies?
   1. Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. Further details can be found at www.opply.io/cookie-policy.
   2. By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for facilitation of optimum performance.  These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
   3. All Cookies used by and on Our Site are used in accordance with the current Cookie Law.
   4. Before Cookies are placed on your computer or device, you will be shown a prompt, requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies
   5. Our Site uses analytics services provided by reputable suppliers. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the services offered through it.
   6. The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
   7. In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
   8. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
   9. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
6. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please contact us on hello@opply.io.

1. Changes to this Privacy Policy
   
   1. We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
   2. Any changes will be immediately posted on Our Site. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated in June 2022.