Privacy Notice

18th November 2022

We are committed to protecting and respecting your privacy. This notice sets out how we look after your data and tells you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below:

1. Introduction

"We", "us" and "our" refer to Open Blend Method Limited. We are incorporated in England (company number 09283273) with our registered offices 90a High Street, Berkhamsted, Hertfordshire, HP4 3NX, UK.

This notice applies when you visit our website: openblend.com, if you sign up to use our OpenBlend Lite services and if you purchase our services. It also applies if we identify you as a prospective customer, as someone who might be interested in what we have to offer or if you supply services to us. These are all situations where we are acting as a data controller with respect to your personal data, that is when we determine why and how your personal data is processed.

This notice does not apply if your employer has asked you to use our services. In this context we only process data on behalf of our customer who is your employer. Your employer is the data controller and we are a data processor. You should view your employer’s privacy notice to understand the basis on which they are processing your personal data.

Our website and services are not intended for children and we do not knowingly collect data relating to children.

Contact us at privacy@openblend.com with any questions in relation to this notice or your privacy rights.

Any changes we make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes.

Our website may from time to time contain links to and from the websites of other businesses. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for their privacy obligations. Please check their privacy notices before you submit any personal data to these websites.

2. The types of data that we collect

Personal information, or personal data, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we collect from various sources as described below:

Identity Data includes first name, last name, title or role and company you work for.
Contact Data includes email address, work details, work address and telephone numbers.
Content Data includes information you enter into our OpenBlend Lite services, and opinions you choose to share with us about using our products and services or when completing surveys about our products and services.
Publication Data includes details you choose to publish via our website or via our LinkedIn page to others including your Identity Data and Contact Data when you provide comment on our blogs or posts, testimonials, interviews or join conversations on our website or LinkedIn page.
Technical Data includes internet protocol (IP) address, 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 to access our website.
Usage Data includes information about how you use OpenBlend Lite, our website and email tracking data about whether you open, or click on links within, our marketing-related emails.
Marketing and Communications Data includes your preferences in receiving marketing communications from us.
Profile Data is data that contributes to building a behavioural profile of you which is built up from a combination of information, for example, your name, company you work for, your online behaviour and browsing patterns, the electronic devices you use, your interests, preferences, demographics, location data, any feedback and survey responses.

We may also collect, use and share Anonymised Data and Aggregated Data such as statistical or demographic data for any purpose. Anonymised and aggregated data may be derived from your personal data but is not considered personal data in law if this data does not directly or indirectly reveal your identity. For example, we may aggregate statistics to understand usage of our websites.

We only collect Sensitive 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, and information about criminal convictions and offences) if you choose to enter that information into our services.

3. How we collect your personal data

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity Data, Contact Data, Marketing and Communications Data, Content Data and Publication Data by signing up for and using our OpenBlend Lite services, by corresponding with us at industry events, by phone, by email, by filling in forms on our website or by posting comments to our website or LinkedIn page. This includes personal data you provide when:
You sign up to and use our OpenBlend Lite services;
You give us your business card, you email us or you contact us through our website;
You request marketing to be sent to you;
You purchase our products and services;
You communicate with us to sell us your products or services;
You register to attend events we organise, sponsor or attend;
You participate in our listening, survey or feedback exercises; or
You provide us with feedback, including comment on our posts and blogs.
Automated technologies or interactions. As you interact with our website and services, we will automatically collect Technical Data about your equipment, browsing actions and patterns and Usage Data about how you interact with our sites and other platforms and whether you open, or click on links within, our marketing-related emails. Technical Data and Usage Data from website visits contributes to our Profile Data. We collect this personal data by using cookies, pixels, server logs and other similar technologies. Please see our Cookie Notice for further details.
Third parties or publicly available sources. We may receive or collect personal data about you from various third parties and public sources as set out below:
Technical Data and Usage Data from analytics providers and from lead generation providers identifying the company IP addresses of our website visitors;
Identity Data and Contact Data shared with us by lead generation service providers and through our referral programme;
Identity Data and Contact Data shared with us by partners such as HR Grapevine through which we undertake marketing campaigns and host or sponsor events;
Identity Data, Contact Data and Profile Data shared with us by partners such as LinkedIn and Google Advertising through which we undertake advertising campaigns; and
Identity Data and Contact Data which we collect from publicly available sources such as LinkedIn, Twitter, press articles and publications, personal blogs and other websites.

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 given your consent to the processing of your personal data for a particular purpose.
Where it is necessary for the performance of a contract with you or to take steps to enter into a contract with you.
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.
Where we need to comply with a legal obligation.

Purposes for which we will use your personal information

The purposes for which we will process your personal information and the lawful basis of processing on which we rely are described below.

Purpose/Activity	Lawful basis for processing including basis of legitimate interest
To build a database of contacts and prospects who might be interested in our products and services and to inform our marketing and sales activities, including market mapping, client and prospect mapping and analysis	Necessary for our legitimate interests (so that we can market and sell our products and services)
To send you our marketing communications and invite you to events and webinars	Your consent (if your consent is required) Necessary for our legitimate interests (so that we can market our products and services to B2B customers)
To follow up sales leads whether sourced by way of demo request, request for information, sign up to our events, by third party lead, from internal research or from our referrals programme	Necessary for our legitimate interests (to qualify sales leads and to make sales of our products and services to grow our business)
To deliver targeted website content and advertisements to you both on our website and via third party platforms (eg LinkedIn and Google) and measure and understand the effectiveness of the advertising we serve to you	Your consent (to the setting of cookies) Necessary for our legitimate interests (so that we can market and sell our products and services to B2B customers)
To administer our referrals programme	Performance of a contract with you
To use data analytics to improve our website, products/services, marketing, user relationships and experiences	Your consent (to the setting of cookies) Necessary for our legitimate interests (to improve our products and services based on user experience, to define types of users for our products and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy)
To provide you with the OpenBlend Lite service you have signed up for including providing the service, sharing your 1-2-1 communications in accordance with your instructions, sending reminders and communications in relation to the service and providing support services	Performance of a contract with you Necessary for our legitimate interests (offering use of OpenBlend Lite and encouraging use of OpenBlend Lite to promote our services more generally)
To process any Sensitive Personal Data you enter when using the OpenBlend Lite services	Your consent (by choosing to enter such information into our OpenBlend Lite service)
To share the names and roles of OpenBlend Lite users with their employing entities	Necessary for our legitimate interests (promoting the sale of our paid for services) Necessary for the employing entity legitimate interests (knowing which of its staff are using a third party HR tool, outside of company provided tools)
To provide you with products and services you have purchased from us or are in negotiations to purchase from us including communications, managing the provision of your services including support services and to manage and collect fees	Performance of a contract with you Necessary for our legitimate interests (to recover amounts due to us)
To administer and support the services you have requested including to send service notifications, manage and support the provision of your services, to manage and collect payments and to exercise our legal rights	Performance of a contract with you Necessary for our legitimate interests (the efficient running of our business and services, to recover amounts due to us and to protect and assert our legal rights)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy notice Asking you to update your information Dealing with any issues or feedback you may have or asking you to complete a survey	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated, to manage and improve our services and the efficient running of our business)
To carry out listening and feedback exercises and surveys to understand user experiences of using our products and services and to provide vouchers or other rewards for participating in such exercises	Performance of a contract with you Necessary for our legitimate interests (to understand user experience of using our products and services so as to inform our product and service development)
To purchase goods and services from you for our business	Necessary for our legitimate interests (to provide and manage our services and the efficient running of our business)
To administer, protect and manage our business and sites (including troubleshooting, business operational analysis, testing, system maintenance, support, reporting and hosting of data)	Necessary for our legitimate interests (for running our business, provision of administration and IT services, business performance analysis, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation

Marketing and Opting out

You may receive our communications or invitations to our events if you have signed up for our OpenBlend Lite services, if you have requested information from us, if you provided us with your details or if we have identified you as someone who may be interested in our products and services and you have not unsubscribed from our marketing communications.

You can unsubscribe from our marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing privacy@openblend.com at any time.

Marketing, advertising and profiling

We build behavioural profiles of potential purchasers of our products and services and use these to identify and target prospects who may be interested in our products and services. We build these profiles from Profile Data we collect about you and use it to send you relevant information about our products and services. We also use it to identify the types of people that are interested in our products and services. We use third-party advertising platforms, such as Google and LinkedIn, to send you advertising messages that are targeted at you, based on your Profile Data. We share your personal information with the third-party advertising platforms, and they will attempt to match your profile in their database to determine when to show you our advertisements. We analyse information from advertising campaigns to understand their effectiveness. In addition, third-party advertising platforms set their own cookies on our website which collect information about your visits to our website and to websites of our competitors. Details of the cookies set and how to manage or decline the setting of advertising and profiling cookies are set out in our Cookie Notice.

You can opt out of targeted marketing and advertising by emailing privacy@openblend.com at any time. We do not make any decisions based on such profiling which produce legal effects on you.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site and target marketing and advertising at interested visitors. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Notice.

In providing our OpenBlend Lite service, we only use essential cookies to enable users to use our service and to keep it secure.

5. Providing your personal data to others

We share your personal data with selected third parties, including:

third party service providers acting as processors who we use to help manage our business. Please email privacy@openblend.com if you would like details of our service providers.
businesses such as LinkedIn and Google who assist us with our advertising and marketing.
Your employer if you are using OpenBlend Lite services
insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims.
taxation authorities, regulators, law enforcement agencies and other authorities if required by such authorities or by due process of law.
third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

We limit the personal data that we share with selected third parties to that which is necessary for them to process for the purposes that we are sharing it.

6. International transfers of your personal data

Your personal information will be processed by us in the UK and the European Economic Area (EEA). Some of your personal data may be transferred, stored and/or processed outside of the UK and the EEA as our suppliers sometimes operate from outside of these jurisdictions. Whenever we transfer your data outside of the UK/EEA we ensure a similar degree of protection is afforded to it by utilising data transfer safeguards prescribed by data protection laws. Please email privacy@openbelnd.com if you would like details of the appropriate safeguards.7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.8. Retaining and deleting personal data

We will retain your personal data for as long as necessary to provide you with our services and for so long as you do not wish to unsubscribe from our marketing communications or from receiving targeted advertising. We will also retain your personal data as necessary to fulfil our contractual obligations and to comply with our legal obligations, resolve disputes, and enforce our agreements.

Where we no longer need to process your personal data for the purposes set out in Section 4 of this privacy notice, we will delete your personal data from our systems unless we need to retain a limited amount of information to make sure that we act in accordance with your wishes.

Where permissible, we will also delete your personal data on your request. Information on how to make a deletion request can be found in Section 9, Your rights.

Please email privacy@openblend.com if you would like details of our retention periods for different kinds of personal data.

9. Your rights

You have certain legal rights with respect to your personal information depending on your location and applicable laws. You may exercise your rights at any time by contacting us at privacy@openblend.com.

Your rights if you are resident in the UK or the EEA

Right of access	You have the right to access any personal data we hold about you: we will provide a copy of your personal data that we hold together with details of the purposes of the processing, the types of personal data we hold and the people to whom your personal data has been disclosed.
Right to rectification	You have the right to have inaccurate or incomplete personal data corrected or to restrict the processing of personal data whilst the accuracy is checked.
Right to erasure	You have the right to ask to have personal data we hold about you erased. 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 law.
Right to data portability	In certain circumstances, you have the right to have data we hold about you transferred to yourself or another data controller. Note, this right only applies to information that is processed by automated means which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to object	You have the right to: ● ask us not to process your personal data for direct marketing purposes ● object, on grounds relating to your particular situation, to the processing of your personal data (including profiling) where we are relying on a legitimate interest .
Right to withdraw consent	You have the right to 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.
Right to complain	You have the right to lodge a complaint with the UK Information Commissioners Office or other data protection supervisory authority applicable to you if you are unhappy with the way we are handling your personal data.

Your rights if you are a resident of California

How We Collect, Use, and Disclose your Personal Information. The types of data that we collect and How we collect your personal data sections of this Privacy Notice describe the personal information we may have collected over the last 12 months, including the categories of sources of that information. We collect this information for the purposes described in the How we use your personal data section. We share this information as described in the Providing your personal data to others section. We use cookies, including advertising cookies, as described in our Cookie Notice.

Your CCPA Rights and Choices. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:

Exercising the right to know. You may request, up to twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:
- the categories and specific pieces of personal information we have collected about you;
- the categories of sources from which we collected the personal information;
- the business or commercial purpose for which we collected the personal information;
- the categories of third parties with whom we shared the personal information; and
- the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.
Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
Exercising the right to opt-out from a sale. You may request to opt out of any “sale” of your personal information that may take place.
Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.
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 may 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.

10. Contact Us

If you have any questions or complaints about this Privacy Notice, please send an email to:

privacy@openblend.com

Or write to:

Open Blend Method Limited

York House,

York Road,

Maidenhead,

SL6 1SF