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Privacy notice and cookies

https://www.oxatis.co.uk - Last update 5/28/2018
Please read this privacy notice (“Privacy Notice”) carefully as it describes our collection, use, disclosure, retention and protection of your personal information.

This Privacy Notice applies to any website, application or service which references this Privacy Notice. Where you provide us with your personal information in any of the ways described in section 2 below, you agree that we may collect, store and use it: 
a) in order to perform our contractual obligations to you; 
b) based on our legitimate interests for processing (i.e. for internal administrative purposes, data analytics and benchmarking (see section 3 below for more information), direct marketing, maintaining automated back-up systems or for the detection or prevention of crime);or
c) based on your consent, which you may withdraw at any time, as described in this Privacy Notice.
1. WHO DOES THIS PRIVACY POLICY APPLY TO?
This Privacy Notice applies to all products, applications and services offered by Oxatis (websites : Oxatis / Marketplace Oxatis / Oxatis Template / Blog), but excludes any products applications or services that have separate privacy notices which do not incorporate this Privacy Notice.
2. How we collect information
To the extent permissible under applicable law, we collect information about you and any other party whose details you provide to us when you:
• register to use our websites, applications or services (including free trials); this may include your surname, first name, title, address, email address and telephone number, and the configuration of your ERP, or when you update your personal details
•complete online forms (including call back requests), take part in webinars, post on our message boards or discussion forums, enter any competitions or prize draws, download information, such as white papers or other publications or participate in any other interactive areas on our website or within our applications or services;
• interact with us using social media;
• provide your contact details to us when signing up to our newsletter
• contact us offline, for example by telephone, fax, SMS, email or post.
We will also collect your information where you only partially complete and/or abandon any information inputted into our website and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.

We may also collect information from your electronic devices (including your mobile phones) and applications used by you or your users to access and use any of our websites, applications or services (for example, we can collect the identification number and the type of device used, geolocation and connection information, such as statistics on pages visited, traffic to and from sites, referral URL, ad data, your IP address, your browsing history, and your web log information). We will ask your advance authorisation before taking steps in any procedure. As such, we may use cookies or other similar means (as described in paragraph 11 below).
We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from credit agencies, search information providers or public sources (e.g. for customer due diligence purposes), but in each case as permitted by applicable laws.

Providing us with information about others
If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Notice.
3. How we use your information
To the extent permissible under applicable law, we use your information to:
• provide, maintain, protect and improve any applications, products, services and information that you have requested from us;
• manage and administer your use of applications, products and services you have asked us to provide;
•manage our relationship with you (for example, customer services and support activities);
• monitor, measure, enhance and protect our content, websites, applications and services and provide you with a personalised and quality user experience; where applicable, we will use a pseudonymised form of any information used for such purposes, and we will ensure that such information is presented in a package and will not be binding on you or any other person concerned;
• perform, internally, checks on our websites, applications, systems and services to test and improve their security, provision and performance;
• provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
• detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and fraud prevention authorities);
• contact you to see if you would like to take part in our customer research (for example, our work in compiling the VSB/SMB e-merchant profile);
• to monitor, carry out statistical analysis and benchmarking, provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual;
• deliver targeted advertising, marketing (including pop-ups) or information to you which may be useful to you, based on your use of our applications and services;
• deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers); and
• provide you with location- based services (for example, advertising and other personalised content), where we collect geo-location data.
To the extent permitted by applicable law, we retain information about you after the closure of your Oxatis account, if your application for a Oxatis account is declined or if you decide not to proceed. This information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.
Our website, applications (including mobile applications) and services may contain technology that enables us to:
• Check specific information from your device or systems directly relevant to your use of the websites, applications or services against our records to make sure the websites, applications or services are being used in accordance with our end-user agreements and to troubleshoot any problems;
• obtain information relating to any technical errors or other issues with our website, applications and services;
• collect information about how you and users use the functions of the features of our website, applications and services; and
• gather statistical information about the operating system and environment from which you access our applications or services.
You can manage your privacy settings within your browser or our applications and services (where applicable).

In addition to the purposes described in this section 3, we may also use information we gather to deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful, based on your use of the website, applications or services or any other information we have about you (depending on the websites, applications or services, you may able to configure these features to suit your preferences). Sections 5 and 6 of this Privacy Notice provides further details on how we will do this.
We may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our website, applications and services you order from us or ask us about, and in order to meet our legal and regulatory obligations generally.
Mobile data
We may obtain information via mobile applications that you or your users install on their mobile devices for the purpose of accessing and using our websites, applications or services, or for the purpose of providing other services related to said mobile application (for example, for the purpose of synchronising information from our application or service with said mobile application). These mobile apps can be our own mobile apps or those of third parties. In the case of a third-party mobile application, you must read the third-party's Privacy Policy as this will be the one applicable to the use of said third-party application. We are not responsible for third-party mobile apps and their use of your personal information.

Mobile applications can provide us with information about their use by the user as well as the use of our applications and services that the user has access to via these mobile applications. We may use this information for the purpose of providing and improving the mobile application or our own services or applications. For example, you can record an action performed with a mobile application.
You can configure the privacy settings of our mobile app on your device, which can affect the performance of the mobile app in question and how it interacts with our apps and services.
Data analytics and benchmarking
We may use information generated and stored during your use of our services for our legitimate business interests to enable us to give you the best service and/or solutions and the best experience. These purposes include to:
• deliver advertising, marketing (including in-product messages via the Intercom solution) or information to you which may be useful to you, based on your use of services;
• carry out research and development to improve our services, products and applications;
• develop and provide new and existing functionality and services (including statistical analysis, benchmarking and forecasting services); and
• provide you with location based services (for example location relevant content) where we collect geo-location data to provide a relevant experience.
Whenever we use your information for our legitimate interests, we will ensure that your information is processed on a pseudonymised basis and displayed at aggregated levels, which will not be linked back to you or to any living individual.

You have the right to object to processing based on our legitimate interests. In such a situation, you will be invited to fill out a 'right to be forgotten' form, or a form to limit the processing of your personal data. If you object to this processing, this may affect our ability to provide certain services and/or solutions for your benefit.
4. Sharing your information
We may share your information with:
• any company within the Oxatis Group, for the purposes set out in this Privacy Notice, (e.g. global information and customer relationship management; software and service compatibility and improvements; and to provide you with any information, applications, products or services that you have requested);
• our service providers and agents (including their sub-contractors) or third parties which process information on our behalf (e.g. internet service and platform providers, payment processing providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the applications, products, services and information you have requested or which we believe is of interest to you;
• partners, including system implementers, resellers, value-added resellers, independent software vendors and developers that may help us to provide you with the applications, products, services and information you have requested or which we believe is of interest to you;
• third parties used to facilitate payment transactions, for example clearing houses, clearing systems, financial institutions and transaction beneficiaries;
• third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites or other third party application providers);
• third parties for marketing purposes (e.g. our partners and other third parties with whom we work and whose products or services we think will interest you in the operation of your business activities. For example, payment solutions providers, delivery agents, SMS service providers;
• reference agents and fraud prevention authorities;
• regulators to meet Oxatis Group’s legal and regulatory obligations;
• law enforcement agencies so that they may detect or prevent crime or prosecute offenders;
• any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
• any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
• our own and Oxatis Group professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
• another organisation if we sell or buy (or negotiate to sell or buy) any business or assets;
• another organisation to whom we may transfer our agreement with you; and
• Government departments where reporting is mandatory under applicable law.
We may share non-personally identifiable information about the use of our website, applications, products or services publicly or with third parties but this will not include information that can be used to identify you.
5. Marketing
From time to time, we may use your information to contact you with details about our applications, products and services which we feel may be of interest to you. We may also share your information with our group companies and carefully selected third parties so that they (or we) may contact you with information about their products or services which we feel may be of interest to you. We or they may wish to contact you for this purpose by telephone, post, SMS or email. You have the right at any time to stop us from contacting you for marketing purposes. You may also request at any time that we do not share your information with third parties referred to in this paragraph. If you wish to exercise these rights you can do so by selecting your contact preferences in your customer account, or by filling in a 'Right to be Forgotten' or 'Limitation of processing' form or when you provide us with your information on our websites, or indeed by unsubscribing from email of SMS communication by clicking on a link contained within these communications.

You can also unsubscribe from any email marketing using the links provided in the emails we send to you.

Your information and your rights

Where you respond to communications we post on third-party platforms (such as Facebook, Google and Twitter or LinkedIn), we may also share your information with those third parties in order to serve targeted advertising/content to you via the relevant third party platform based on your profile/interests.  Your information is used by the third-party platform provider to identify your account and serve advertisements to you.  You can control what advertisements you receive via the privacy settings on the relevant provider’s platform and you should consult the third party’s help/support centre for more information.
6. Your information and your rights
If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:
• the right to be told how we use your information and obtain access to your information;
• the right to have your information rectified or erased or place restrictions on processing your information;
• the right to object to the processing of your information e.g. for direct marketing purposes or where the processing is based on our legitimate interests;
• the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
• where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
• the right to object to any decisions based on the automated processing of your personal data, including profiling; and
• the right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in the UK, the Information Commissioner’s Office).
If we hold any information about you which is incorrect or if there are any changes to your details, please let us know by so that we can keep our records accurate and up to date.

If you withdraw your consent to the use of your personal information for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our website, applications, and services.

We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in conformity with the applicable European legislation. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).
I wish to limit the processing of my data: Make the request
I wish to benefit from the right to be forgotten: Make the request
I wish to apply the portability of my data or modify it: Make the request
7. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. However we will not reduce your rights under this Privacy Notice. We will always update this Privacy Notice on our website, so please try to read it when you visit the website (the ‘last updated’ reference tells you when we last updated this Privacy Notice).
8. Security and storage of information
We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal information but we cannot guarantee the security of your information which is transmitted to our website, applications or services or to other website, applications and services via an internet or similar connection. If we have given you (or you have chosen) a password to access certain areas of our websites, applications or services please keep this password safe – we will not share this password with anyone.

If you believe your account has been compromised, please contact our customer service department via the usual client channels
9. Transfers outside of the European Economic Area
The Oxatis infrastructure is hosted in a secure data centre built and operated in France.
We may use service providers based outside of the EEA in order to ensure that we can maintain contact with you in the context of your e-Commerce activity.

We take steps to ensure that where your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures and controls in place to protect that information in accordance with applicable data protection laws and regulations. For example, we may share information with our group companies or affiliates based outside the EEA for the purposes envisaged by this Privacy Notice. All Oxatis Group companies are subject to Oxatis group data protection policies designed to protect data in accordance with EU data protection laws. In each case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.

By using our website, products or services or by interacting with us in the ways described in this Privacy Notice, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Notice. If you do not want your information to be transferred outside the EEA you should not use our website, applications or services.
10. Other sites and social media
If you follow a link from our website, application or service to another site or service, this Privacy Notice will no longer apply. We are not responsible for the information handling practices of third party sites or services and we encourage you to read the privacy notices appearing on those sites or services.

Our websites, applications or services may enable you to share information with social media sites, or use social media sites to create your account or to connect your social media account. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third party social media account(s) to manage what personal information you enable us to access from that account.
11. Cookies, Analytics and Traffic Data
During your first visit to our website we are obliged to install cookies on your computer, tablet or mobile. These cookies may be installed by us or by the service providers that operate on our behalf and the information collected is only used for our benefit. Cookies allow us:
• to optimise your navigation and the functioning of our services
• to carry out studies and statistics about the frequentation of our site
• to process your requests via the contact forms
You can set your computer, tablet or mobile phone to notify you each time a cookie is sent to you. If you want, you can disable all cookies. This can be done in your browser settings. If you disable cookies, you will not have access to many features that make your experience as a customer easier, and some of our websites, apps and services will not work properly.

In accordance with current legislation, cookies can not be kept for more than 13 months.
Accepting the information banner or continuing your navigation implies acceptance of our cookie policy.
However, you can always disable cookies as described below.
• Chrome browser: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en
• Firefox Browser: https://support.mozilla.org/en/kb/clear-cookies-to-delete-information
• Internet Explorer : https://support.microsoft.com/uk-ua/help/278835/how-to-delete-cookie-files-in-internet-explorer
• Safari browser: https://support.apple.com/kb/PH19214?locale=en_UK&viewlocale=en_GB
We use the following different types of cookies:
• Strictly necessary cookies : Oxatis platform cookies
These are cookies which are needed for our websites, applications or services to function properly, for example, these cookies allow you to access secure areas of our website, to buy apps or graphic design templates on our Market Place in the context of your e-Commerce activity.

• Functional cookies: how are they used?
These cookies allow our websites, applications and services to remember your choices (such as your username, your language or the region where you are located) and to offer improved, more personal features. These cookies can also be used to remember changes you made to the font or font size as well as other customisable sections of web pages. They can also be used to provide you with the services you have requested. The information collected by these cookies can be made anonymous; in addition, these cookies do not allow you to follow your browsing activity on other websites.

• Performance cookies and analytics technologies
These cookies collect information about how visitors and users use our websites, applications and services, for instance which functionality visitors use most often, and if they get error messages from areas of the websites, applications or services. These cookies don't collect information that identifies a visitor or user. All information these cookies collect is aggregated and therefore anonymous. We only use these cookies to improve how our website, applications and services work.

Google analytics Cookies
Google Analytics uses "cookies", to help the website analyse how users use the websites, applications or services. The information generated by the cookie about your use of the websites, applications or services (including your IP address) will be transmitted to and stored by Google on servers in the United States.Google will use this information for the purpose of evaluating your use of the websites, applications or services compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser or within the application, however please note that if you do this you may not be able to use the full functionality of this website. By using our websites, applications or services you consent to the processing of data about you by Google in the manner and for the purposes set out above. To find out more, see “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time).
To opt out of being tracked by Google Analytics across all websites visit:http://tools.google.com/dlpage/gaoptout.

Hotjar Cookie
Oxatis uses the Hotjar solution to anonymously record customer journeys on our websites. The IP address, navigation data, device and browser used facilitate analysis and improvement of the actual customer experience on Oxatis group sites in all the technical configurations encountered.

Cookie AB Tasty
Oxatis uses AB Tasty solution to conduct marketing and statistical tests (called A/B tests) on its websites. This solution allows us to collect statistical visitor data which is subsequently retrieved in an aggregated and anonymous way in a web interface to which only the Oxatis Marketing department, as AB Tasty customers, has access. With the data collected, Oxatis is able to improve the user experience on its site and the quality of the customer journey. For more information, see: https://www.abtasty.com/gdpr-compliance/


• Targeting or advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operators’ permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

Facebook cookies: are used to be able to offer you different advertising messages on the Facebook social network depending on whether you have visited our site or not. For more information on this cookie, see https://www.facebook.com/policies/cookies/

LeadsTheWay cookies: are used to identify visitors to the site and pages visited in order to contact them. For more information on this cookie, see https://www.lead-the-way.fr/donnees-personnelles.html

Criteo cookies: are used to create a base audience and retarget visitors with advertisements when they browse other sites. More information on https://www.criteo.com/privacy/

Bing Ads cookies: are used to become acquainted with our visitors coming from advertising campaigns on the Bing text ad network when they sign up to the Oxatis e-Commerce solution. More information on https://privacy.microsoft.com/en-us/privacystatement

Google Adwords cookies:are used to become acquainted with our visitors from ad campaigns on the Adwords text ad network when they sign up to the Oxatis e-Commerce solution. More information on https://cloud.google.com/security/gdpr/

Capterra affiliated partner cookies:are used to become acquainted with our visitors from sponsored blog posts or e-Commerce partners (eg Capterra) when they sign up to the Oxatis e-Commerce solution. More information on https://www.capterra.com/legal/privacy-policy


• Web beacons and parameter tracking
We also use cookies and similar software known as web beacons to count users who have visited our website after clicking through from one of our advertisements on another website or in emails and to collect details of any products or services purchased. These web beacons collect limited information which does not identify particular individuals. It is not possible to refuse the use of web beacons. However, because they are used in conjunction with cookies, you can effectively disable them by setting your browser to restrict or block cookies.

• IP Address and traffic data
We keep a record of traffic data which is logged automatically by our servers, such as your Internet Protocol (IP) address, device information, the website that you visited before ours and the website you visit after leaving our site. We also collect some site, application and service statistics such as access rates, page hits and page views. We are not able to identify any individual from traffic data or site statistics.
12. Additional information: Address of the Data Protection Officer (DPO)
If you have any queries about how we treat your information, the contents of this Privacy Notice, your rights under local law, how to update your records or how to obtain a copy of the information that we hold about you, please send an e-mail to dataprotection@oxatis.com.