Privacy Policy

    Aqua hand

    Introduction

    We are OKO (which is a trading name of Ready For Business Ltd, a limited company registered in England and Wales under company registration number 12719696) and our registered office is at Swift Farm Sandy Lane, Great Chart, Ashford, England, TN26 1JN (referred to as OKO, we, us or our).

    We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use the OKO mobile application software, OKO for business console and website (Platform) and tell you about your privacy rights and how the law protects you.

    This privacy policy, together with our end-user licence agreement (EULA), applies to your use of the Platform and will inform you as to how we look after your personal data when you use the Platform (regardless of how you access it) and tell you about your privacy rights and how the law protects you.

    This privacy policy provides information on the personal data we process in respect of the following categories of individuals:

    • users of the Platform designated as mentors (Mentor(s));
    • users of the Platform designated as mentees (Mentee(s)); and
    • users of the Platform designated as company representatives or programme managers (Administrator(s)).

    1. Important Information and Who We Are

    Purpose of this privacy policy

    This privacy policy aims to give you information on how we collect and process your personal data through your use of the Platform.

    The Platform is not intended for use by children below the age of 18 years old and we do not knowingly collect data relating to children.

    It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

    This privacy policy supplements other notices and privacy policies and is not intended to override them.

    Controller

    We are the controller and responsible for your personal data. By this we mean that we determine the purposes for which and the manner in which your personal data is, or is to be, processed.

    Contact details

    We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, our privacy practices or want to submit a request to exercise your legal rights, please contact the data privacy manager using the details set out below:

    Name of data privacy manager: David Evans
    Email address: support+dataprivacy@weareoko.com
    Postal address: Swift Farm Sandy Lane, Great Chart, Ashford, England, TN26 1JN

    You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

    Changes to the privacy policy and your duty to inform us of changes

    We keep our privacy policy under regular review. This version was last updated on 21st March 2022 and historic versions can be obtained by contacting us.

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

    Third-party links

    The Platform may, from time to time, include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Platform, we encourage you to read the privacy policy of every website or application you visit.

    2. The Data We Collect About You

    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

    We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

    Identity Data includes first name, last name, username or similar identifier, job title, date of birth, and photographs that you use for display photos.

    Contact Data includes email address and telephone numbers.

    Technical Data (a) where you access the Platform via the mobile app, includes the type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting; and (b) where you access the Platform via the web browser, includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use.

    Content Data includes your account biography.

    Profile Data includes your username and password, history, preferences and feedback, and psychometric test results and personality profile information.

    Usage Data includes details of your use of the Platform including, but not limited to, traffic data and other communication data and the resources that you access.

    Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences (including notification preferences).

    Your Profile Data includes your psychometric test results and personality profile information. When you register as a Mentor or a Mentee we will ask you to complete a psychometric test so that we can match you with a Mentee or a Mentor (as appropriate) with similar personality scores. This is carried out using automated processes and algorithms.

    We regularly test our algorithms to ensure that the process remains fair, effective and unbiased.

    If you would like us to reconsider any decision made automatically, please contact us at support@weareoko.com.

    We may also collect, use and share Aggregated Data from time to time such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

    We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

    If you fail to provide personal data

    Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to our Platform). In this case, we may have to cancel your registration to the Platform but we will notify you if this is the case at the time.

    3. How Is Your Personal Data Collected?

    We will collect and process the following data about you:

    • Information you give us. This is information (including Identity, Contact, Profile and Marketing and Communications Data) you consent to giving us about you by filling in forms on the Platform, completing the psychometric test or by corresponding with us (for example, by email). It includes information you provide when you download or register to use the Platform, search for the Platform and when you report a problem with the Platform. If you are a Mentor, some of this information may be provided on your behalf by your employer when they sign you up as a Mentor. If you contact us, we will keep a record of that correspondence.
    • Information we collect about you and your device. Each time you use the Platform we will automatically collect personal data including Technical, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
    • Information we receive from other sources including third parties. We will receive Technical, and Usage Data from analytics providers such as Google Inc., based outside of the UK.

    Cookies

    We use cookies and/or other tracking technologies to distinguish you from other users of the Platform and to remember your preferences. This helps us to provide you with a good experience when you use the Platform and also allows us to improve the Platform.

    If you prefer not to allow the use of cookies, you can change the confirmation on the browser to either warn you when you receive a cookie or to automatically reject them. You may find, however, that disabling cookies means certain areas of the site do not function correctly.

    For more information on the cookies used on our website and web apps, please see below.

    Third Party Cookies used by OKO

    On our website:

    Cookies player, vuid
    Provider Vimeo
    Purpose To enable playing video via the video player.

    Cookies _ga, _ga_XXX, __utma, __utmc, __utmz
    Provider Google
    Purpose To allow recording of website usage and behaviour.


    OKO web app:

    Cookies player, vuid
    Provider Vimeo
    Purpose To enable playing video via the video player.

    Cookies utmstat_click_id, quickblox-_zldp, _hjid, utmstat_hostname,_ga, utm_referrer,_fbp
    Provider QuickBlox
    Purpose To allow operation of the chat function.

    Cookies _ga, _ga_XXX, __utma, __utmc, __utmz
    Provider Google
    Purpose To allow recording of website usage and behaviour.


    OKO for Business Console:

    Cookies _ga, _ga_XXX, __utma, __utmc, __utmz
    Provider Google
    Purpose
    To allow recording of website usage and behaviour.

    Cookies __stripe_mid,__stripe_sid, stripe.csrf, user, site-auth, cid,__stripe_mid, lang, machine_identifier, _ga, merchant, private_machine_identifier, _gcl_au, __stripe_orig_props, recent-views, docs.prefs
    Provider Stripe
    Purpose To allow operation of the payment gateway.

    4. How We Use Your Personal Data

    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    • Where you have consented before the processing. Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us;
    • Where we need to perform the contract we are about to enter into or have entered into with you or, where applicable, the business which you represent. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract;
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. and/or
    • Where we need to comply with a legal obligation. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

    We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us at support@weareoko.com.

    We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

    You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

    Purposes for which we will use your personal data

    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

    Purpose/activity

    Type of Data

    Lawful basis for processing

    To sign up as a Mentor or Mentee

    (a) Identity

    (b) Contact

    (c) Technical

    (a) Your consent

    (b) Performance of a contract with you or your employer

    To enable full functionality of the Platform e.g. allowing your Mentor/Mentee to see the information about you and filter searches and to match you as a Mentor/Mentee

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Technical

    (e) Usage

    (f) Content

    (a) Your consent

    (b) Performance of a contract with you

    To manage our relationship with you including notifying you of changes to the Platform

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Marketing and Communications

    (a) Your consent

    (b) Performance of a contract with you

    (c) Necessary for our legitimate interests (to keep records updated and to analyse how customers use our Platform)

    (d) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions or privacy policy)

    To administer and protect our business and the Platform including troubleshooting, data analysis and system testing

    (a) Identity

    (b) Contact

    (c) Technical

    (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

    (a) To deliver content and advertisements to you;

    (b) To measure and analyse the effectiveness of the advertising we serve you;

    (c) To monitor trends so we can improve the Platform

    (a) Identity

    (b) Contact

    (c) Technical

    (d) Content

    (e) Profile

    (f) Usage

    (g) Marketing and Communications

    (a) Consent

    (b) Necessary for our legitimate interests (to develop our Platform and grow our business)


    Change of purpose

    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at support@weareoko.com.

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

    5. Disclosures of Your Personal Data

    We may share a limited amount of your personal data with the Mentor/Mentee you have been matched with securely through the platform.

    Any third-party service that is granted access to the personal data is required to treat it in accordance with the law and with respect to the security of the data. Third-party service providers are not allowed to use your personal data for their own purposes and they must only process the data for purposes that are in accordance with our instructions.

    6. International Transfers

    When some of the third parties identified in section 5 above are based outside the United Kingdom (UK), or have group or affiliated companies based outside of the UK, their processing of your personal data may involve a transfer of data outside the UK.

    Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

    • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
    • Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

    Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

    7. Data Security

    All information you provide to us is stored on our secure servers.

    Where you have chosen (or we have given you) a password that enables you to access certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

    Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

    Certain services may include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

    8. Data Retention

    We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

    To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

    In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

    In the event that you do not use the Platform for a prolonged period of time then we may treat the account as expired and your personal data may be deleted.

    9. Your Legal Rights

    Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

    Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

    • If you want us to establish the data's accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with access to our Platform. We will advise you if this is the case at the time you withdraw your consent.

    Object to automated profiling and monitoring. You have an absolute right to withdraw your consent to us processing your Profile Data for the purposes of determining which Mentor or Mentee (as appropriate) to match you with. We rely on your explicit consent to profile you in this way. If you wish to withdraw your consent, we will not be able to provide you with access to our platform.

    You also have the right to ask us not to continue to process your personal data for marketing purposes.

    You can exercise any of these rights at any time by contacting us at support@weareoko.com.

    No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

    What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.