Your Digital Wellbeing Platform
Thank you for your interest in this Privacy Policy! At Oxyzn, we take the protection of your data very seriously, and in the below we explain what data we collect when you use our website and services and how it is used.
General Information
In principle, we will only use your personal data in accordance with the applicable data protection laws, in particular the UK`s Data Protection Act (“DPA”) and the EU counterpart the General Data Protection Regulation (“GDPR”).
The responsible party within the meaning of the DPA and the GDPR is Oxyzn Ltd of 82 College Place, London, London, NW1 0DJ, United Kingdom (“Oxyzn“, “we”, “us”, or “our”).
If you have any questions or if you wish to exercise your rights, please feel free to email alexandra@oxyzn.net, call +447541730850, or write to us at the above address
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website.
Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing.
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data:
Data we collect automatically
Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user’s device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.
The hosting services used by us for the purpose of operating our website is WPEngine, Inc.. In doing so WP Engine, processes inventory data, contact data, content data, usage data, meta data and communication data of customers, interested parties and visitors of our website and services, on the basis of our legitimate interests in an efficient and secure provision of the website and services in conjunction with the provision of contractual services and the conclusion of the contract for our services, including but not limited to our services).
We use the Content Management System (CMS) of WordPress by Automattic Inc, to publish and maintain the created and edited content and texts on my website. This means that all content and texts submitted to my website is transferred to WordPress. The legal basis for this processing is our legitimate interest.
We also use a Content Delivery Network (CDN) to distribute our online content. Our CDN is a network of regionally distributed servers operated by our technical service providers that are interconnected via the Internet. When you visit our website, your device’s browser transmits information to these service providers, which is collected in corresponding server log files. The server log files are usually anonymized and then transmitted without personal reference. The server log files include in particular i) information on the browser and operating system used, ii) the previously visited pages (so-called referral URL), iii) the IP address of the device used, iv) the name of the Internet provider, and v) the date, time of all page views including the amount of data transferred. The legal basis for the processing is our legitimate interest.
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).
As set out in the UK`s Privacy and Electronic Communications Regulations (“PECR”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.
Our website uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.
Please note that if you use a link from our website to a third-party website, that third-party may also set new cookies that are not covered by this policy. In such cases, we recommend that you read the cookie policy on the third-party website itself.
We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services.This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.
The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any,
YouTube Videos
We have integrated components (video) from YouTube. The integration requires that YouTube can perceive the IP address of the user. The IP address is required in order to send the video content to the user’s browser. If you click on a YouTube component on our website, your internet browser will be prompted by the component to download a corresponding representation of the component. In this way, YouTube knows which specific sub-pages you have visited. The legal basis for the data processing is our legitimate interest and your consent.
Data we collect directly
In addition to your name, company name (if any), and e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and contract.
We are present on social media (currently LinkedIn, YouTube Twitter, Facebook and Instagram). If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contract.
We use the service of Calendly, Inc. for the simplified booking of appointments. By using this service, the data you submit including your Name, Email address and IP Address is transferred to Calendly. The processing of the data entered via Calendly is thus exclusively based on a legitimate interest of simplified appointment arrangement and the initiation of a contract. The data entered by you remains with us until you request us to delete it or the purpose for storing the data no longer applies.
As part of the registration process, users provide their Full Name, Title, Email address, Password phone number and company or business details, if any, and special category data such as Injuries and Health Issues (optional) and other information about their preferences. The data provided will be used for the purposes of creating and using the account and providing and/or using our services. In the context of the use of our registration and the use of your account, the legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as consent.
When using our services, you become the data controller and we become the data processor in accordance with Part 3 Chapter 4 of the DPA and Chapter 4 of the GDPR. Where we process your Personal Data as data processor or in other words on behalf of you, we will process the Personal Data involved in your use of our services in accordance with your instructions and shall use it only for the purposes agreed between you and us.
We process the Personal Data involved in your use of our services in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfil our legal obligations.
We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly.
We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
For optimal data management and customer support, we may store the data related to your use of our services with us in our customer relationship management system. This data processing is based on our legitimate interest in providing our customer service.
We also use Zoom (Zoom Video Communications, Inc.) to conduct our online meetings, consultations, wellness events and to provide support. When using Zoom various types of data are processed. The scope of the data depends on the information you provide before or during the online meeting. The processing bases are your consent as well as my legitimate interest.
If you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out. The legal basis for processing is the initiation of a contract, our legitimate interest and your consent.
For business reasons, we analyse the data we have on business transactions, contracts, enquiries,browsing behaviour etc., whereby the group of persons concerned may include contractual partners, interested parties, and users of our services.
The analyses are carried out for the purpose of business evaluations and market research. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymized values. Furthermore, we take the privacy of users into consideration and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as summarised data).
Principles of processing Personal Data
At the time of data collection, for example in the context of a contractual relationship we process and store Personal Data from you. We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.
We do not sell your Personal Data.
We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services and, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfil our legitimate interests.
We may transfer your Personal Data to other companies and/or staff members as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.
Your Rights and Privileges
Under the DPA and GDPR, you can exercise the following rights:
If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner’s Office (ICO) is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK www.ico.org.uk
Changes
We may update this policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.
Contact us
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us using alexandra@oxyzn.net.
Effective Date
Thursday, 8th of June 2023