Open ECX Customer GDPR Policy
This notice applies to if you are one of our individual customers, a prospect, an employee of a customer or a group company of a customer or an individual who is relevant to our work for clients.
We are committed to respecting your privacy. This notice is to explain how we may use personal information that is provided to us or which we collect before, during and after our customer relationships with our clients.
The protection of your personal information is important to us. We respect your privacy and want to understand what we do with the information we hold about you.
What information do we collect?
We collect information about you when you complete voluntary forms on our website and associated landing pages in order to gain access to content such as datasheets, case studies, videos etc. We also collect information when you register for webinars and events, complete surveys, use our web chat or enquire through our online forms. Website usage information is collected using cookies (details available on request).
We may collect:
- Contact details: information that allows us to contact you directly such as your name, email address, telephone number and addresses
- Payment information: credit/debit card details and bank account details you provide so that we can make payments to you or receive payments from you
- Records of your interactions with us: such as telephone conversations, letters and other correspondence (including e-mail)
- Your marketing preferences: so that we know whether and how we should contact you
- Where we request any of the personal information described above from you, you are not required to provide any such information, however, if you do not do so, we may not be able to properly provide our services to our customers.
How will we use the information?
We collect information about you in order to manage customer accounts, handle your webinar/event registration, deal with your enquiry and to contact you about other products and services that we think would be of interest to you. We also use the information for analysis with a view to administering, supporting, improving and/or developing our website, and the product and services we offer. In addition, we may contact you to ask for feedback on any product, services or website.
We may process your personal information for our legitimate business interests. e.g. direct marketing/data analytics/enhancing, modifying or improving our services/identifying usage trends/determining the effectiveness of promotional campaigns and advertising.
We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research and data analysis. Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing if you wish, and if you wish to do so please e-mail email@example.com. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit.
What is ‘legitimate business interests’?
‘Legitimate Interests’ means the interests of our company in conducting and managing our business [to enable us to give you the best service/products and the best and most secure experience]. For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that is tailored to your interests.
When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative) and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
What we use your personal information for:
|Purpose||Personal information used||Lawful basis|
|Provide our services to clients||> All the personal information we collect||This is necessary to fulﬁl our contract with customers.|
|Make payments to you and receive payments from you||> Transaction and payment information||This is necessary to fulﬁl our contract with customers or is otherwise done with your consent.|
|Answer your queries or complaints||> All the personal information we collect||We have a legal obligation to provide complaint handling services.|
|Staff training||> All the personal information we collect||We have a legitimate interest to improve the services we provide.|
|Perform credit checks||> Contact details|
> Payment information
|This is necessary to enter into a contract with customers.|
|Perform anti-money laundering checks||> Your contact details||We have a legal obligation to do so.|
|Determine products and services that may be of interest to you||> All personal information we collect (but not your payment information)||We have a legitimate interest to identify new services that may be of interest to you.|
We send our customers marketing communications based on legitimate interest and the soft opt-in rule in the PECR. You can opt out of these communications at any time and they will not affect any service related communication from our operations team.
|Investigating fraud and debt collection||> All the personal information we collect||We have a legitimate interest in so doing.|
|Development new products and services|
Sources from which we collect your personal information
We collect personal information from a number of sources. These include:
- Directly from you: when you complete forms we provide to you, contact us via our support desk, make a complaint, contact us by phone, email or communicate with us directly in some other
- Other companies we work with: provide us with information to help us deliver our services to you These include:
- Our customers who may instruct us to connect our services to your company.
- Companies in the same group of companies as us: who may provide relevant information about your
- Companies that are relevant to a customer project: for example, a third-party supplier working on a project involving one of our customers may give us your contact details so that we may more easily communicate with
- Companies in the business of supplying data lists: the personal data we acquire is processed on the lawful basis of ‘legitimate interest’.
- Credit reference agencies: provide us with information on your creditworthiness.
- Public registers: such as the land registry or companies house provide us with information relevant to our customer
Sharing your information
We share personal information with the following parties:
- Companies in the same group of companies as us: for the purpose of providing a service to you
- Other legal or professional advisors: where relevant for a customer service.
- Any party approved by you or our customers
- Credit reference agencies
- Other service providers and advisors: such as companies that support our business, help us analyse the data we hold, process payments, send communications to our clients, provide us with legal or ﬁnancial advice and generally help us deliver our services to you
- Purchasers of our business: buyers or prospective buyers who we sell or negotiate to sell our business to
- The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives for the ﬁnancial services industry, including but not limited to the Financial Conduct Authority and Prudential Regulation Authority
- Police and law enforcement: to assist with the investigation and prevention of
We do not disclose personal information to anyone else except as set out above.
Email, post, SMS and telephone marketing: from time to time, we may contact you by email, post or telephone with information about products and services of ours and/or our partners which may be of interest to you.
We send marketing communications on the basis of ‘legitimate business interest’ (see previous) and the soft opt-in allowed by the Privacy and Electronic Communications Regulations (PECR).
You can let us know at any time that you do not wish to receive marketing messages by emailing firstname.lastname@example.org. You can also unsubscribe from our marketing by clicking on the unsubscribe link in the marketing messages we send to you.
If you actively consent to receiving information from us, you may still opt out at a later date.
How long do we keep your personal information for?
We will keep your personal information for as long as our relevant project or service is progressing. After that project or service has completed we will keep your personal information for a reasonable period to maintain our records and satisfy our legal, tax or regulatory obligations, or other legitimate and lawful business purposes. Where we no longer need your personal information, we will dispose of it in a secure manner (without notifying you).
Access to your information and correction
In accordance with the Data Protection Act 1998 you have the right to access any information that we hold relating to you.
We want to make sure that your personal information is accurate and up to date.
You have the following rights in relation to your personal information:
- the right to be informed about how your personal information is being used
- the right to request we provide you with any personal information we hold about you
- the right to opt-out of receiving direct marketing messages
- the right to request the correction of inaccurate personal information
- the right to request the blocking or deletion of your personal information where the processing does not comply with applicable data protection laws
- the right to request that we port elements of your data either to you or another service provider
Supply of such personal information that we hold about you will be subject to:
- 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)
We may withhold such personal information to the extent permitted by law.
You may instruct us not to process your personal information for marketing purposes by sending an email to us at email@example.com.
Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the ‘How to contact us’ section below.
If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint ﬁrst.
How to contact us