How we obtain Personal Data

The information we process about you includes information:

• you have directly provided us
• as a result of monitoring how you use our website or our platform

Types of Personal Data we collect directly

When you use our website, our platform or buy from us, for example when you create an account on our platform, we ask you to provide Personal Data. This can be categorized into the following groups:

• Personal identifiers, such as your first and last names and your title
• Contact information, such as your email address, your telephone number and your postal addresses for billing delivery and communication
• Account information, including your username and password
• Payment information
• Records of communication between us including messages sent through our website, platform, or email messages
• Marketing preferences that tell us what types of marketing you would like to receive

Types of Personal Data we collect from third parties

We confirm some of the information you provide to us directly using data from other sources. We also add to the information we hold about you, sometimes to remove the need for you to provide it to us and sometimes to be able to assess the quality of the services you offer.

The additional information we collect can be categorised as follows:

• Information that confirms your identity
• Business information, including your business trading name and address, your company's registered number (if incorporated) and your VAT number (if registered)
• Information that confirms your contact information
• Reviews and feedback about your business on other websites through which you sell your services
• Unsolicited complaints by other users

Types of Personal Data we collect from your use of our services

When you are using our website and our platform, we process:

• Your username and password and other information used to access our website and our platform
• Information you contribute to our community, including reviews
• Your replies to polls and surveys
• Technical information about the hardware and the software you use to access our website/platform and use our services, including your Internet Protocol (IP) address, your browser type and version and your device's operating system
• Usage information, including the frequency you use our services, the pages of our website or platform that you visit, whether you receive messages from us and whether you reply to those messages
• Transaction information that includes the details of the products and services you have bought from us, and payments made to us for those services (payments are processed by our Service Provider - Stripe)
• Your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your Personal Data, and to notify you of the basis for each category.

If a basis on which we process your Personal Data is no longer relevant, then we shall immediately stop processing your data.

Information we process because we have a contractual obligation with you

When you create an account on our website or platform, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

To carry out our obligations under that contract we must process the information you give us. Some of this information may be personal data.

We may use it to:

• verify your identity for security purposes when you use our services
• sell products to you
• provide you with our services
• provide you with suggestions and advice on products, services and how to obtain the most from using our website and platform

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or platform or ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be Personal Data.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website and platform.

We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us  dataprotection@ocumetra.com. However, if you do so, you may not be able to use our website or our services further.

We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether to process your Personal Data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your Personal Data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.

Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having considered:

• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

• improving our services
• record-keeping for the proper and necessary administration of our business
• responding to unsolicited communication from you to which we believe you would expect a response
• preventing fraudulent use of our services
• exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
• insuring against or obtaining professional advice that is required to manage business risk
• protecting your interests where we believe we have a duty to do so

Information we process because we have a legal obligation

Sometimes, we must process your information to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorization such as a search warrant or court order.

This may include your Personal Data.

Sharing of your personal data

We only share your personal data with some authorized third-party vendors and service providers to help us provide the services to you.

Service providers and business partners

We may share your Personal Data with businesses that provide services to us, or with business partners.

They may include:

• Support and customer service software providers, such as the software our team uses to communicate with you when you report a bug.
• Security or regulatory consultants who help us make our systems as safe to use as they can be.

Service Providers are contractually required to only handle your data in ways that we specify, including being contractually prohibited from selling your data.

Payment information

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of Stripe or some other reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.

Job application and employment

If you send us information in connection with a job application, we may keep it for up to 3 years in case we decide to contact you later.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

Use of information we collect through automated systems

Some of our web pages use cookies. Cookies are small text files that are stored on your computer and saved by your browser. Cookies help make our website and platform more user-friendly, efficient, and secure. Cookies do not harm your computer and do not contain any viruses.

You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Disabling cookies may limit the functionality of this website and platform.

We use the following types of cookies:

• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily and to see how effective and relevant advertising on our website is.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or location) and remember if we have already asked you for feedback or to complete a survey.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

Managing and disabling cookies

Any cookie that is not Strictly Necessary is not active by default and does not send information to the resource it is called from. Accepting all cookies, makes all cookies active. You can modify your cookie preferences for the website at any time by clicking on the "Cookie Settings" button below.

Analytics and third-party tools

When visiting our website or platform, statistical analyses may be made of your surfing behavior. This happens primarily using cookies and analytics. The analysis of your surfing behavior is anonymous, i.e., we will not be able to identify you from this data. The data collected on this website and Ocumetra platform is processed through the JotForm Inc., which is a GDPR and HIPAA compliant service.

Server log files

We collect and store information that your browser automatically transmits to us in "server log files". These are:

• Browser type and browser version
• Operating system used
• Referrer URL
• Host name of the accessing computer
• Time of the server request
• IP address

We use this information in aggregate to assess the popularity of the webpages on our website or platform and how we perform in providing content to you.

Plugins and tools

Our website and platform make use of third-party plugins and tools including but not limited to:

• YouTube
• Google Maps
• Adobe Typekit

The purpose of these plugins and tools is to make our services informative and appealing. We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover information practices of these third parties.

Other matters

Your rights

The law requires us to tell you about your rights and our obligations to you regarding the processing and control of your Personal Data.

We do this now, by requesting that you read the information provided here.

Use of our services by children

We do not sell products or provide services for purchase by children, nor do we market to children.

Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser's URL bar or toolbar.

Delivery of services using third party communication software

With your consent, we may communicate with you using software provided by a third party such as Google (GMail) or Microsoft (Teams).

Such methods of communication should secure your Personal Data using encryption and other technologies. The providers of such software should comply with all applicable privacy laws, rules, and regulations, including the GDPR.

If you have any concerns about using a particular software for communication, please tell us.

Data processing outside the European Union

Ocumetra does not transfer data outside of the European Union. Our website and platform are hosted on AWS which offers the facility to choose the geographic region of data storage. Additionally, AWS offers strong encryption for data at rest or in transit and offers customers the option to manage their own encryption keys.

Control over your own information

It is important that the Personal Data we hold about you is accurate and up to date. Please inform us if your Personal Data changes.

At any time, you may review or update personally identifiable information that we hold about you, by signing into your account on our platform (www.mcp.ocumetra.com)

To obtain a copy of any information that is not provided on our platform you should contact us to make that request.

When we receive any request to access, edit or delete Personal Data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Please be aware that we are not obliged by law to provide you with all Personal Data we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

If you wish us to remove personally identifiable information from our platform, you should contact us to make your request.

This may limit the service we can provide to you.

We remind you that we are not obliged by law to delete your Personal Data or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.