PRIVACY POLICY

One Cycle Limited (OneCycle, Onecycle) ("Company", "we" or "us") based at 30 - 31 St James' Place, Mangotsfield, Bristol, BS16 9JB is responsible for your personal information and we take our data protection and privacy responsibilities seriously.

This Privacy Policy explains how we collect, use and share personal information in the course of our business activities, including:

  • What personal information we collect and when and why we use it.

  • How we share personal information within Company and with our service providers, regulators and other third parties

  • Explaining more about Direct Marketing

  • How we protect and store personal information

  • Cookies

  • Legal rights available to help manage your privacy

  • How you can contact us for more support

 

Updates

 

We may amend this Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business, and will place any updates on this webpage. This Privacy Policy was last updated on 29th May 2020. Please regularly check these pages for the latest version of this notice.  If we make fundamental changes to this Privacy Policy, we will seek to inform you by notice on our website or email. 

 

Third Party Websites

 

You might find external links to third party websites on our website. This Privacy Policy does not apply to your use of a third party site

WHAT PERSONAL INFORMATION WE COLLECT AND WHEN AND WHY WE USE IT

 

In this section you can find out more about

  • the types of personal information we collect

  • when we collect personal information

  • how we use personal information

  • the legal basis for using personal information

When we collect information

We collect information about you if you:

  • use our website or online questionnaire or contact us;

  • are the subject matter of or relevant to the scope of our inquiries;

  • work with us as a member of the inquiry or our advisory team;

collectively ("you").

 

If you use our websites

If you use our website, we will collect, use and share personal information about you for the following purposes:

  • To allow you access to certain Promotional material/content available on our website.

  • Location data. Certain services may involve the use of your location data. Use of your location data is, however, subject to your prior consent for each service.

  • Personal data obtained from third parties. We may obtain personal data about you from third party sources such as social media analytics, and from the following partners:

 

Digital RFQ an FCA registered EMD Agent https://digitalrfq.com )

The personal information we use includes :

  • To allow us to provide you with the correct specific information you have requested, or to communicate with you, we may ask you to provide us with certain information such as your name, date of birth or age, email address, home or postal address, or financial situation. In registering on our website, you may create user names, passwords and other credentials that we use to authenticate you and to validate your actions. You may send us copies of your personal identity documents or details about other financial products to which you may be a party.

  • We also ask you to identify what type of potential investor you are under the Financial Services and Markets Act 2000 (Financial Promotions) Order 2005.

 

Legal basis for using your personal information

 

We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

  • we need to use your personal information to perform a contract or take steps to enter into a contract with you.

  • we need to use your personal information for our legitimate interest as a commercial organisation. For example, we may record calls to our customer service centre so that we can review how we handle calls and make any necessary improvements.  In all such cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in link to the Legal Rights section below;

  • we need to use your personal information to comply with a relevant legal or regulatory obligation that we have.  For example, Financial Services and Markets Act 2000 (Financial Promotion) Order 2005.

If you would like to find out more about the legal basis for which we process personal information please contact us / click here

 

SHARING PERSONAL INFORMATION OTHERS

 

In this section you can find out more about how we share personal information:

  • within Company

  • with third parties that help us provide our products and services; and

  • government organisations and agencies, law enforcement and regulators

We share your personal information in the manner and for the purposes described below:

  • with other companies within our group, where such disclosure is necessary to provide you with our products or and services or to manage our business.

  • with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include IT service providers who help manage our IT and back office systems;

  • with government organisations and agencies, law enforcement, regulators, which may include the Information Commissioner's Office, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;

  • banks and payment providers to authorize and complete payments;

  • with credit reference agencies and organisations working to prevent fraud in financial services;

  • we may share in aggregate, statistical form, non‑personal information regarding the visitors to our website, traffic patterns, and website usage with our partners, affiliates or advertisers.

If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business or assets.

EXPLAINING MORE ABOUT DIRECT MARKETING

 

In this section you can find out more about

  • how we use personal information to keep you up to date with our products and services.

  • how you can manage your marketing preferences

 

How we use personal information to keep you up to date with our products and services

We may use personal information to let you know about our products and services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you. 

How you can manage your marketing preferences

To protect privacy rights and to ensure you have control over how we manage marketing with you:

  • we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;

  • you can ask us to stop direct marketing at any time ‑ you can ask us to stop sending email marketing, by following the "unsubscribe" link you will find on all the email marketing messages we send you. Alternatively you can contact us at info@onecyclegroup.com. Please specify whether you would like us to stop all forms of marketing or just a particular type (eg email); and

  • you can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained.

 

We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences within your account with us.

 

HOW WE PROTECT AND STORE YOUR INFORMATION

Security

We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned.

Measures we take include:

  • placing confidentiality requirements on our staff members and service providers;

  • destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected; and

  • following strict security procedures in the storage and disclosure of your personal information to prevent unauthorised access to it; and

  • using secure communication transmission software (known as "secure sockets layer" or "SSL") that encrypts all information you input on our website before it is sent to us.  SSL is an industry standard encryption protocol and this ensure that the information is reasonably protected against unauthorized interception.

 

As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect User IDs and passwords, please take appropriate measures to protect this information.

Storing your personal information

We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Privacy Policy. Where your information is no longer needed, we will ensure that it is disposed of in a secure manner. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements Subject to any actual or potential legal claim or regulatory investigation, the maximum time that we envisage retaining any of your information is seven years, after which time it will be destroyed.

In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

COOKIES

A cookie is a small text file containing small amounts of information which is downloaded to / stored on your computer (or other internet enabled devices, such as a smartphone or tablet) when you visit a website.

Cookies may collect personal information about you. Cookies help us remember information about your visit to our website, like your country, language and other settings. Cookies allow us to understand who has seen which webpages and advertisements, to determine how frequently particular pages are visited and to determine the most popular areas of our website.They can also help us to operate our website more efficiently and make your next visit easier. Cookies can allow us to do various other things, as explained further in our Cookie Policy which you can access by clicking on the link below. 

For more information about how our cookies work and information about how to manage your cookie settings please visit our Cookie Policy.

 

LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. Click on the links below to learn more about each right you may have:

 

 

 

 

 

 

 

 

If you wish to access any of the above mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

 

You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request. 

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

 

Right to access personal information

You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information  may be transferred.

Right to rectify or erase personal information

You have a right to request that  we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information  before rectifying it.

  • You can also request that we erase your personal information in limited circumstances where:

  • it is no longer needed for the purposes for which it was collected; or

  • you have withdrawn your consent (where the data processing was based on consent); or

  • following a successful right to object (see right to object); or

  • it has been processed unlawfully; or

  • to comply with a legal obligation to which the Company is subject.

 

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:

  • for compliance with a legal obligation; or

  • for the establishment, exercise or defence of legal claims;

 

Right to restrict the processing of your personal information

 

You can ask us to restrict your personal information, but only where:

  • its accuracy is contested, to allow us to verify its accuracy; or

  • the processing is unlawful, but you do not want it erased; or

  • it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or

  • you have exercised the right to object, and verification of overriding grounds is pending.

 

We can continue to use your personal information following a request for restriction, where:

  • we have your consent; or

  • to establish, exercise or defend legal claims; or

  • to protect the rights of another natural or legal person.

 

Right to transfer your personal information

You can ask us to provide your personal information to you in a structured, commonly used, machine‑readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

  • the processing is based on your consent or on the performance of a contract with you; and

  • the processing is carried out by automated means.

 

Right to object to the processing of your personal information

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection,  we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to object to how we use your personal information for direct marketing purposes

 

You can request that  we change the manner in which we contact you for marketing purposes.

You can request that  we not transfer your personal information  to unaffiliated third parties for the purposes of direct marketing or any other purposes.

Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal information  is transferred outside of the European Union.

 

We may redact data transfer agreements to protect commercial terms.

 

Right to lodge a complaint with your local supervisory authority

You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.

 

We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time. 

 

CONTACT US

The primary point of contact for all issues arising from this Privacy Policy is our Legal & Commercial Officer. The Legal & Commercial Officer can be contacted in the following ways:

 

Via email: info@onecyclegroup.com

Subject title: Privacy Matters

 

Write to us at: Onecycle Limited, Privacy Matters, 30 - 31 St James' Place, Mangotsfield, Bristol, BS16 9JB.

 

If you have any questions, concerns or complaints regarding our compliance with this Privacy Policy, the information we hold about you or if you wish to exercise your rights, we encourage you to first contact us. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

To contact your data protection supervisory authority

 

You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement), which in the UK is the Information Commissioner's Office at any time (contact here : https://ico.org.uk/global/contact-us/ ).

 

We ask that you please attempt to resolve any issues with us before your local supervisory authority.

Issue Date of Privacy Policy: 29th May 2020