1.1 We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.
2. How we use your personal data
2.1.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.1.2 We may process data about your use of our website and services ("**usage data**"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.1.3 We may process your account data ("**account data**"). The account data may include your name email address, organization, postal address, telephone number or other contact details. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing or offering our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.1.4 We may process your information included in your personal profile on our website ("**profile data**"). The profile data may include your name, and employment details. The profile data may be processed for the purposes of delivering our service to you and other users of our service. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and service.
21.5 We may process your personal data that are provided in the course of the use of our services ("**service data**"). The service data may include information relating to your manufacturing operations and potential actions that you could take to improve their performance. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, service and business.
2.1.6 We may process information that you post for publication on our website or through our services ("**publication data**"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, service and business.
2.1.7 We may process information contained in any enquiry you submit to us regarding products and/or services ("**enquiry data**"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.
2.1.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("**notification data**"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.1.9 We may process information contained in or relating to any communication that you send to us ("**correspondence data**"). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, service and business and communications with users, customers or potential customers of our service.
2.1.10 We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.1.11 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.2 Data processors
|Subprocessor||Data location and security||Service|
|Amazon Web Services (AWS) - Cloud Computing Services||Dublin, Ireland||Secure Hosting Infrastructure for servers, databases, logs, and user generated content.|
2.3 Third parties
|Matomo||To collect and analyse information about how you interact with our websites (web analytics)||Legitimate interest||Anonymised IP address, Pages visited, browser and device used||matomo.org/privacy-policy/|
|Rollbar||To collect and analyse any error that has happened during your session||Legitimate interest||IP address, Pages visited, browser and device used, username used||docs.rollbar.com/docs/privacy-policy|
|Scanii||To scan uploaded files against malwares (viruses, trojans, worms, etc)||Legitimate interest||username used, contents of any uploaded file||docs.scanii.com/privacy-policy.html|
|SendGrid||To notify of application events and to send periodic statistics||Explicit consent||first name, e-mail address, message sent, user provided content (action titles, facility names, ...)||sendgrid.com/policies/privacy/|
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
3.2 We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of obtaining professional advice and managing legal disputes.
3.3 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for the proper delivery of our services to you.
3.4 Financial transactions relating to our website and services may be handled by our payment services providers, Paypal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. We do not store credit card details. You can find information about the payment services providers' privacy policies and practices at [https://www.paypal.com/en/weba...](https://www.paypal.com/en/webapps/mpp/ua/privacy-full)
3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person
3.6 We may disclose elements of your profile data to other users of M2030 bee where this is necessary in order to deliver the service effectively to you and other users.
3.7 Except as identified in this clause 3, we will not share your details with any 3rd parties
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 Some of our subcontrators may _be_ situated in the United States. Transfers to any such subcontractors will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, or participation in the Privacy Shield agreement.
4.3 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain and delete your personal data as follows:
(a) _Usage data_ will be retained for _1 year_ following _the end of your use_, at the end of which period it will be deleted from our systems.
(b) _Account data_ will be retained for _1 year_ following _the end of your trial of or subscription to our service_, at the end of which period it will be deleted from our systems.
(c) _Profile data_ will be retained _for 1 month_ after _you request deactivation of your profile_, at the end of which period it will be deleted from our systems.
(d) _Service data_ will be retained for _1 month_ following _the end of your trial of or subscription to our service_, at the end of which period it will be deleted from our systems.
(e) _Publication data_ will be retained for _5 years_ following _the end of your use_, at the end of which period it be deleted from our systems.
(f) _Enquiry data_ will be retained until _you cancel your notification subscriptions_, at the end of which period it will be deleted from our systems.
(g) _Notification data_ will be retained for _3 years_ following _the end of your use_, at the end of which period it will be deleted from our systems.
(g) _Correspondence data_ will be retained for _5 years_ following _its creation_, at the end of which period it will be deleted from our systems
5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email.
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims
7.8 In practice, you will expressly agree in advance to our use of your personal information for marketing purposes, and we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). You may instruct us at any time not to process your personal information for marketing purposes, and can do so by email at [email@example.com](mailto:firstname.lastname@example.org)
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
10. Managing cookies
10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
10.2 Blocking all cookies will have a negative impact upon the usability of many websites.
10.3 If you block cookies, you will not be able to use all the features on our website.
11. Our details
11.1 This website is owned and operated by 2degrees Limited
11.2 We are registered in England and Wales under registration number 06485099, and our registered office is at 9400 Garsington Road, Oxford Business Park, Oxford, OX4 2HN
11.3 Our principal place of business is at 228-240 Banbury Road, Oxford OX2 7BY
11.4 You can contact us:
(a) by post, using the postal address of our principal place of business;
(b) by email, using the email address [email@example.com](mailto:firstname.lastname@example.org)
12. GDPR and California Consumer Privacy Act (CCPA)
12.2 California Consumer Privacy Act (CCPA)
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”
(a) We collect this information for the business and commercial purposes described in section '2. How we use your personal data' above.
(b) We share this information with the categories of third parties described in the 2.3 'Third parties' section.
(c) We do not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). We do not use third-party cookies for advertising purposes.
(d) Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
(e) California consumers may make a request pursuant to their rights under the CCPA by contacting us at email@example.com. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf