Oxford Computer Group LLC Privacy Policy

Our commitment to your privacy

We at Oxford Computer Group LLC (OCG) are committed to protecting the privacy of our website users, customers and prospective customers.

Our privacy policy below explains in detail how we collect, store and handle personal data in order to offer you the best service we can. Here is a quick summary of some key points:

We will never sell, rent or otherwise disclose your personal data to any third party except where it is necessary to provide you with services you have requested, and only then for that purpose.
We will protect your personal data against loss and unauthorized access using appropriate security measures.
You can unsubscribe from marketing communications at any time, either by clicking the unsubscribe button at the bottom of marketing emails, or by sending an email to privacy@oxfordcomputergroup.com.
You can ask us to let you know what personal information we hold about you and ask for it to be deleted.

If you have any questions, please contact us:

Email: privacy@oxfordcomputergroup.com
Phone: 877-862-1617
Mail: Oxford Computer Group, 22722 29th Drive SE, Ste. 100, Bothell, WA 98021

Privacy Policy: quick links

Introduction

We are committed to safeguarding the privacy of visitors to our website at oxfordcomputergroup.com, our prospective customers and our customers.

In this policy, “OCG”, “we”, “us” and “our” refer to Oxford Computer Group LLC. We are part of the Oxford Computer Group family of companies that shares a common brand and values, and that specialize in identity lifecycle management, identity-driven security, and identity governance.

We offer consultancy solutions to organizations in North and South America, and offer webinars, blogs and whitepapers to enable IT professionals to keep up to date with our services, the latest technologies and best practices.

This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

How we use your personal data

In this table we have set out information about how we use your personal data and the legal bases of that use.

Data category	Source of data	Purposes for which we use the data	Legal basis of processing
Usage data (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)	Our analytics tracking system	Analyzing the use of our website and services	Our legitimate interests*, namely monitoring and improving our website and services
Prospective customer data and customer data (information relating to our relationships with customers and prospective customers, including contact information, which may include payment preferences, job/role information, information about attendance at webinars, events and training courses)	You or your employer	Operating and maintaining our website, managing our relationships with customers and prospective customers, facilitating orders and bookings, communicating with customers and prospective customers, keeping records of those communications and promoting, marketing and selling our services, and those of our group of companies, to customers and prospective customers	Our legitimate interests* namely the proper administration of our website and business and the management of our customer relationships
Order and services data (information relating to transactions, including orders for our consultancy services, which may include your name, your contact details and transaction-specific details such as the date of the transaction and the details of the order and information related to the services provided)	You or your employer	Supplying the services, communicating with you in relation to the order, managing orders, and generally and keeping proper records of transactions	The performance of a contract* between you and us and/or taking steps, at your request, to enter into such a contract AND/OR Our legitimate interests*, namely the supply of our services and the proper administration of our website and business
Communications data (communication content and metadata associated with the communication)	You, although our website will generate the metadata associated with communications made using the website contact forms.	Communicating with you and record-keeping	Our legitimate interests*, namely the proper administration of our website and business and communications with customers, prospective customers and users

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense 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.

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests*, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal data set out in this policy, 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.

Please do not supply any other person’s personal data to us unless we prompt you to do so.

*See the glossary at the end of this policy for more information.

Creating profiles

‌We may analyze your personal data to create a profile of your likely interests and preferences. We may use the profile to determine whether to send you communications, and the content of such communications. We may make use of additional information about you when it is available from external sources to help us do this effectively (such as information on your or your employer’s website).

Providing your personal data to others

We will not sell, rent or otherwise disclose your personal data to any third party for their marketing purposes without your express consent.

We may disclose your personal data to Oxford Computer Group Worldwide trading as OCG Learning and Oxford Computer Training and other members of our group of companies (this means those companies operating under the Oxford Computer Group brand) insofar as reasonably necessary for the purposes, and on the legal basis, set out in this policy.

We may disclose your personal data to our services providers and subcontractors (including our website hosting services providers, our marketing database providers, our webinar providers, and our order and payment services providers) insofar as reasonably necessary for the purposes, and on the legal basis, set out in this policy. Please contact us for the most up-to-date list, if required.

We may disclose details of your event bookings to event and venue operators and to other third-party services providers for the purpose of enabling those third parties to provide their services to you.

We may disclose your personal data to our 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 defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

In addition to the specific disclosures of personal data set out above, we may 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Extra-EEA transfers of your personal data

If you are a citizen of a country within the EAA doing business directly with OCG, the following section applies to you:

OCG has offices and facilities in the US. Our other group companies have offices within the EEA. Transfers between the US and the EEA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

Some of our services providers and subcontractors use facilities situated outside the EEA. Save as specified below, we will ensure that all extra-EEA transfers to services providers and subcontractors are either:

to jurisdictions that provide adequate protection for personal data; or
are protected by appropriate safeguards, namely the standard contractual clauses adopted or approved by the European Commission, the Privacy Shield scheme and/or binding corporate rules.

Please contact us if you would like details of the appropriate safeguards we use.

If you book or are booked to attend a training course in the US or an event outside the EEA, then we will send your name together with selected account and customer data on a need-to-know basis to relevant event and venue operators and to other third party services providers situated in the US or outside the EEA in order for them to provide services to you. By booking you acknowledge that such transfers may not be protected by appropriate safeguards.

Retaining and deleting personal data

The table below 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.

In general, 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.

Data category	Retention period
Usage data	A period of 30 months following collection
Prospective customer data	A maximum period of 18 months following our last interaction with the prospective customer
Customer data	A minimum period of 6 years following the end of the year during which the last contract between us and the customer terminated or expired, and for a maximum period of 7 years following that date
Order data	A minimum period of 6 years following the end of the year during which the relevant transaction occurred, and for a maximum period of 7 years following that date
Communications data (excluding data which is also prospective customer data or customer data)	A maximum period of 3 years following the end of the year in which the communication occurred

We may in any case 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.

Security of personal data

We will take appropriate technical and organizational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

Amendments

We may update this policy from time to time by publishing a new version on our website. We may notify you of significant changes to this policy by email or via our website.

Your rights

We have summarized below 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.

Legal right	Brief description
The right to access	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.
The right to rectification	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.
The right to erasure	You may have the right to the erasure of your personal data without undue delay.
The right to restrict processing	You may have the right to restrict the processing of your personal data.
The right to object to processing	You may have the right to object to our processing of your personal data on grounds relating to your particular situation.
The right to data portability	You may have the right to receive your personal data from us in a structured, commonly used and machine-readable format.
The right to complain to a supervisory authority	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.
The right to withdraw consent	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.

Third party websites

Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

Personal data of children

Our website and services are targeted at persons over the age of 16. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

Updating information

Please let us know if the personal information that we hold about you needs to be corrected or updated.

About cookies

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.

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.

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.

Cookies that we use

We use cookies for the following purposes:

authentication – we use cookies to identify you when you visit our website and as you navigate our website;
status – we use cookies to help us to determine if you are logged into our website;
personalization – we use cookies to store information about your preferences and to personalize our website for you;
security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally; and
cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Cookies used by our services providers

We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

Managing cookies

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:

https://support.google.com/chrome/answer/95647?hl=en (Chrome);
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
http://www.opera.com/help/tutorials/security/cookies/ (Opera);
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
https://support.apple.com/kb/PH21411 (Safari); and
https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

Our details

This website is owned and operated by Oxford Computer Group LLC. We are a registered LLC in the State of Washington. Our registered office is at Oxford Computer Group, 22722 29th Drive SE, Ste. 100, Bothell, WA 98021.

You can contact us:

By email: privacy@oxfordcomptuergroup.com
By phone: 877-862-1617
By mail: Oxford Computer Group, 22722 29th Drive SE, Ste. 100, Bothell, WA 98021

Glossary

Legitimate interest means the processing of your personal data is necessary for the purposes of a legitimate interest of our business or a third party and that your interests, rights and freedoms do not override that legitimate interest. 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 the purposes of our legitimate interests or those of a third party. We do not use your personal data for activities where our interests are overridden by a negative impact on you. If you contact us, we can provide you with further details on why we consider this to be the most appropriate legal basis.

Legal obligation or legal basis means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.

Performance of a contract means processing your personal data where it is necessary for the performance of a contract with you or, at your request, taking preparatory steps to perform such a contract.

Your privacy is our priority

Oxford Computer Group LLC is committed to protecting your privacy and to securing your personal data.