Last Updated: July 2024
Privacy & Cookie Policy
Introduction
Your privacy is important to Origination Global Ltd. This policy sets out information on the personal data we collect about you, and your rights in respect of this data. This policy applies whether you attend one of our events (an “Event”) or use our website (https://origination.global) (the “Website”).
Our Website may contain links to third party websites that are not covered by policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.
If you have any comments on this policy, please email them to privacy@origination.global
This policy contains the following information (you can access a specific section of this policy by clicking below):
• Information about who we are
• Information on what we can collect
• Information on cookies
• How we store your personal data
• How we disclose your information
• Your rights regarding your personal data
• What happens when we link to other websites
• The changes we may make to the policy
Who We Are
Our company name is Origination Global Ltd, trading as The Virtual Event Company. Our registered address is 7 Albert Court, Prince Consort Road, Kensington, London SW7 2BJ. If you wish to speak to someone about the policy, please contact John Saunders on hello@origination.global
We respect your right to privacy and will only process personal information about you in accordance with applicable data protection laws. We comply with General Data Protection Regulation (2016/679) and the UK Data Protection Act 2018. If any of these laws are replaced or superseded, we will also comply with that.
What we may collect
Personal data, or personal information, is 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 when you use our Website or attend one of our Events. Whenever we collect personal data about you, we must have a legal ground to do so.
When you create an account on our Website
When you create an account with us, we will ask you to provide your email address and name. It is your decision whether to provide your full name.
We use this information to allow you to sign into an account on our Website. The legal basis for us collecting this information is legitimate interest – the information is required to protect your online account.
If you contact a member of our team to discuss customer service matters, we will use your name and email address when we interact with you. The legal basis we have for this is to provide you with assistance regarding customer service matters.
We will then use your name and email address to send you information about your account (including changes to this policy or security information) or an Event which you have signed up to attend. Our legal basis for using your name and email address int his way is to provide you with relevant information relating to the security of your online account, and also to ensure you have up-to-date information on how we handle your personal data.
We may ask you whether you want to opt-in to our marketing information. If you say yes to this, we will use your email address to provide you with marketing information about our products and services. Our legal basis for this is that you have provided your consent. You can withdraw your consent at any time by contacting us at hello@origination.global
When you attend one of our Events
When you sign up attend one of our Events, you will be asked to provide your name and email address (as set out above). This allows us to identify you when you attend the Event. Our legal basis for this is legitimate interest, to ensure that only those who have signed up to attend an Event participate in that Event.
If we are providing a virtual event which includes refreshments or meals provided as part of the Event, we will ask for your address details and information on your dietary requirements. The legal basis for us collecting this information is to perform a contract with you – we are offering a service which includes providing meals and/or refreshments to you in person and, in order to do so, we will require your address and information on your dietary requirements. You do not have to provide this when we request it, but it means we will be unable to provide this element of the Event to you.
We will never 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). If this changes, we will update this policy, and ask for your consent to process this information.
We do not collect any personal information about anyone under the age of 16.
Information on cookies
We use cookies in accordance with the Privacy and Electronic Communications Regulations (implementing the EU Directive 2002/58/EC).
Cookies are small text files placed on your device when you visit our site and are used to make the users experience more efficient. We are able to store cookies on your computer where they are necessary for the operation of the site however, for non-essential cookies we need your permission.
We use cookies to distinguish users and to improve our Website. We analyse how you use our website, and we look at aggregate statistics about your usage, and how others use our Website. We collect certain information from these cookies, and this includes information about your IP address, your location when you access the Website, the date and time you access the Website, the language you use and the type of browser you use.
We do not track individual users or use cookies to identify individuals. We use cookies to recognise you and your preferences, improve our site’s performance and collect analytical information for ourselves and our business partners. Without the knowledge gained we would not be able to provide the service we do.
These are the types of cookies we use.
‘Session cookies’ allow us to track your actions during a single browsing session, but they do not remain on your device afterwards
‘Persistent cookies’ remain on your device between sessions. We use them to authenticate you and to remember your preferences. We can also use them to balance the load on our servers and improve your experience on our Website
Session and persistent cookies can be either first or third party cookies. A first-party cookie is set by the Website being visited; a third-party cookie is set by a different website. Both types of cookie may be used by us or our business partners.
The third party cookies we use are:
Google Analytics – this is a web analytics service provided by Google, Inc. The cookies used by Google Analytics help us to analyse how users use our website and to count the number of people who use it. Google Analytics stores your IP address anonymously. Google does not associate your IP address with any personally identifiable information
Facebook Ads – these cookies collect information about how visitors use our website. This data is collected anonymously and is used to help improve our website’s functionality
Google Ad Words – these cookies collect information about how visitors use our website. This data is collected anonymously, to help make our marketing communications more relevant, and is used to improve our website’s functionality
All our cookies are categorised by the role they fulfil on our Website:
Strictly Necessary: these are essential to enable you to move around our Website and use features such as secure services. Without these cookies such services could not be provided;
Functionality: allow the website to remember your choices and to personal certain features. These cookies may be anonymised and cannot track your browsing activity on other websites; and
Performance: collect information as to how users use the Website. These cookies don’t collect information that identifies a visitor. The information collected is aggregated and used to improve our Website.
None of the cookies employed are classified as Behavioural Targeting.
We will always ask for your consent to use non-essential cookies. You are free to withhold consent to this, but it means that we might not be able to provide the full Website experience to you, including some Events.
If at any time you wish to disable our cookies, you may do so through the settings on your browser, or whenever the pop-up appears on our Website (each time you access the Website).
How we store your personal data
We store all your personal data on our servers within the United Kingdom.
We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and to receive our services and deal with payment. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA.
Where we use providers based in the US, we may transfer data to them if we have in place standard contractual clauses with them. Where this is the case, we undertake regular due diligence on these providers to ensure they comply with the General Data Protection Regulation.
Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. 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. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We will still be responsible for protection of your personal data, even where we have transferred it outside the EEA.
We usually delete personal data following an Event, unless our client has specifically asked us to keep the data for future Events. In such cases, we will keep personal data for as long as is necessary, which is usually the life of our relationship and up to a period of seven years after our relationship has ended. But we may be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements.
We regularly review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.
How we disclose your information
We may disclose your information in the following cases:
If we want to sell our business, or our company, we can disclose it to the potential buyer
We can disclose it to other businesses in our group, as defined in the Companies Act 2006
We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights
We can exchange information with others to protect against fraud or credit risks
We may contract with third parties to supply services to you on our behalf. These include cloud services used to send emails and technology providers that assist in providing the Events to you.
Your rights
When you provide us with personal data, you have certain legal rights, and these include:
To request access to, deletion of or correction of, your personal data held by us at no cost to you
To request that your personal data be transferred to another person (data portability)
To be informed of what data processing is taking place
To restrict processing
To object to processing of your personal data
To complain to a supervisory authority
If you wish to access, rectify, erase or transfer your personal data, please contact us at hello@origination.global
What happens when we link to other websites
This privacy policy only relates to our Website and our Events. We might have links on our Website to other websites, and these websites will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those website.
Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our Website. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
The changes we may make to this policy
We can update this policy from time to time as laws change or as our Events or Websites change. If we make material changes to the policy, and we need your consent to those changes, we will contact you by email to do so.