WHO ARE WE?
Immense Simulations Limited, Alchera Data Technologies Limited and Oxford Computer Consultants Limited (together “Box5) have worked together on a development project procured by Oxfordshire County Council to create a cloud-based software solution called Modelling Infrastructure and Mobility as a Service or “MIMAS.” Immense now wishes to offer subscription licences to MIMAS on behalf of Box5. This document sets out how Box5 will process the personal data of the employees, agents and contractors of its Customers. The details of Box5 are set out at Schedule 1 to this policy.
The companies which form Box5 are Joint Data Controllers in relation to the processing activities described below. The details below describe how we collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others, and how it is kept secure.
HOW WE COLLECT YOUR PERSONAL INFORMATION
When you use this website, our products or services, we collect certain personal data about you. The type of personal data we collect is information:
- you provide to us; and
- we collect from you;
- we observe about you (from your interaction with our email campaigns and/ or website);
- we obtain from other sources, including our group companies and other third parties; and
Personal information you give to us:
This is information about you that you give to us by entering information via our site www.mimas.services, our mobile applications, social media platforms and corresponding with us by phone, email, event and conference stands or otherwise and is provided entirely voluntarily.
- Information provided at the time of subscribing to our newsletter, including your name and email address.
- Information provided at the time of requesting a demonstration or consultation of the MIMAS platform or to ask a general question on the Immense website, or at an event including your name, email address, employer organisation and telephone number.
- If you contact us online, including to report a problem with the MIMAS platform, we will collect your name and contact details keep a record of your email or relevant correspondence.
Personal information we collect about you:
We may automatically collect the following information: details of transactions you carry out on your visits to MIMAS, including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources you access. We may also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
We may also collect any personal information which you allow to be shared that is part of your public profile or third party social network, type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Please see Cookies for further information. We may also collect any personal information which you allow to be shared that is part of your public profile or third party social network, type and version, time zone setting, browser plug-in types and versions, operating system and platform.
HOW WE USE YOUR PERSONAL INFORMATION
We may use and process your personal information where you have consented for us to do so for the following purposes:
You may withdraw your consent for us to use your information in any of these ways at any time.
Where it is in your VITAL INTEREST
Where we have supplied you with any services and software, we may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.
Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests, or that of a third party, for the following purposes:
Where there is PERFORMANCE OF A CONTRACT
We may use your personal information where it is necessary for the performance of a contract (including the provision of training, accreditation and support), this includes where you (or your employer) subscribes to MIMAS and appoints you as an Authorised User, along with our providing any associated services under a contract with your employer, for which you may be the appointed representative. Our use of personal information in this context includes where we take steps at your (or your employer’s) request before entering into such a contract.
Where there is a LEGAL REQUIREMENT
We will use your personal information to comply with our legal obligations: (i) to assist with queries raised by a public authority or criminal investigation body; (ii) to identify you when you contact us; (iii) to verify the accuracy of data we hold about you; and/or (iv) where we reasonably believe that you are or may be in breach of any applicable laws, we may disclose your personal information relevant third parties, including to law enforcement agencies.
DATA ANONYMISATION AND USE OF AGGREGATED INFORMATION
Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for analytical and research purposes.
OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION
Oxfordshire County Council
We may share your information with Oxfordshire County Council in order that they may provide training and accreditation to Authorised Users of MIMAS. They may use your personal information in the ways set out in How we use your personal information .
Our suppliers and service providers
We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers (such as hosting and email management), marketing agencies and administrative services.
When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions. A list of our third party service providers is set out at Schedule 2 to this policy.
As satisfaction for people who engage with us is important to us, we may ask a third-party research company to contact you for the sole purpose of gathering general information and specific information relating to us and our products and services.
Other ways we may share your personal information
We may transfer your personal information to a third party as part of a sale of some or all of our businesses and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.
WHERE WE STORE YOUR PERSONAL INFORMATION
As an organisation with an international presence the personal data which we collect may be transferred to and stored in countries outside the jurisdiction you are in, including to some of our group companies, suppliers and service providers. Any international transfers of your personal information are made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to enquire about these safeguards used, please contact us using the details set out at the end of this policy.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your personal information above. The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing below); or
- in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
SECURITY AND LINKS TO OTHER SITES
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.
- Accessing your personal information
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
- Correcting and updating your personal information
The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.
In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.
- Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information[JR19] [RN20] , you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
- Objecting to our use of your personal information and automated decisions made about you
Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as set out under How we use your personal information, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please opt out from receiving marketing emails by unsubscribing from our database. You can find the unsubscribe link at the bottom of any marketing email which we send.
You may also contest a decision made about you based on automated processing by writing to us at the address at the end of this policy.
- Erasing your personal information or restricting its processing
In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.
You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
- Transferring your personal information in a structured data file (“data portability”)
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under How we use your personal information , you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
- Complaining to the UK data protection regulator
You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.
We may review this policy from time to time and any changes will be notified to you by posting an updated version on the MIMAS user interfact. Any changes will take effect 7 days after the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy whenever you visit the MIMAS user interfact. If you do not agree with any aspect of the updated policy you must immediately notify us and cease using our services.
Please direct any queries about this policy or about the way we process your personal information to our data privacy manager using our contact details below.
If you wish to write to us, please write to the address given at the start of this policy.
Our data privacy manager’s email address for data protection queries is email@example.com.