Privacy
Otherway.com (our website) is provided by Otherway London Limited (trading as Otherway) (‘we’,‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
This privacy policy is divided into the following sections:
- What this policy applies to
- How your personal data is collected
- Personal data we collect about you
- How and why we use your personal data
- Marketing
- Who we share your personal data with
- How long your personal data will be kept
- Transferring your personal data out of the UK
- Cookies and other tracking technologies
- Your rights
- Keeping your personal data secure
- How to complain
- Changes to this privacy policy
- How to contact us
What this policy applies to
This privacy policy relates to your use of our website only.
Throughout our website we may link to other websites owned and operated by certain trusted third parties to share information about other brands and businesses and to other media or publishing sites. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
- your name, address and contact information, including email address and telephone number and company details
- details of any information, feedback or other matters you give to us by phone, email, post or via social media
- your activities on, and use of, our website
- information about the services we provide to you
- your contact history, purchase history and saved items
- information about how you use our website and technology systems
- your responses to surveys, competitions and promotions
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect personal data from you:
- Directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase products or services, and...
- indirectly, such as your browsing activity while on our website; we will collect information indirectly using the technologies explained in the section on ‘Cookies’ below.
How and why we use your personal data
We need to collect your personal data in order to:
- provide our platform and services to you
- gather feedback to improve our services
- enforce legal rights or defend or undertake legal proceedings
- ensure our business policies are complied with
- improve efficiency, training and quality control
- ensure the confidentiality of commercially sensitive information
- help us manage our business through statistical analysis, eg in relation to our customer base, our product range and for efficiency improvements
- prevent unauthorised access and modifications to our platform and services
- protect the security of systems and data used to provide the services
- update and enhance customer records
- Market our services to:some text
a. existing and former customers;
b. third parties who have previously expressed an interest in our services;
c. third parties with whom we have had no previous dealings. - External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts
Our legal basis for processing your data
We will process your data for the purposes described in this policy, based on the following legal grounds:
- We process your data in order to provide a service you’ve asked for under a contract.
- We process your data for our legitimate interests and those of third parties while applying appropriate safeguards that protect your privacy.
- We process your data when we have a legal obligation to do so.
- We ask for your consent to process your data for specific purposes and you have the right to withdraw your consent at any time.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us at hello@otherway.com
using the ‘unsubscribe’ link in emails or ‘STOP’ number in textsWe may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never share it with other organisations outside the Otherway group for marketing purposes.
Who we share your personal data with
We routinely share personal data with:
- third parties we use to help deliver our services to you, eg payment service providers
- other third parties we use to help us run our business, eg website hosts and website analytics providers
- our banks
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above occasionally also share personal data with:
- our external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
If you stop using your account we will delete or anonymise your account data after seven years or otherwise in accordance with our then current data retention policy.
Transferring your personal data out of the UK
The EEA, UK and other countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.
We will transfer your personal data to:
- our service providers located outside the UK, and
As we are based in the UK we will also transfer your personal data from the EEA to the UK.
Under data protection laws, we can only transfer your personal data to a country outside the UK where:
- in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
- a specific exception applies under relevant data protection law
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) eg legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
If you would like further information about data transferred outside the UK, please contact us (see ‘How to contact us’ below).
Cookies
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies and similar technologies, on our website. These help us recognise you and your device and store some information about your preferences or past actions.
For further information on cookies and any similar technologies, our use of ‘cookies’ and similar technologies, when we will request your consent before placing them and how to disable them, please see our Cookies Policy.
Your rights
You generally have the following rights, which you can usually exercise free of charge
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
- the Information Commissioner in the UK, and
- a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA
The Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.
How to contact us
Individuals in the UK
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Otherway
15B St George's Mews,
London NW1 8XE
hello@otherway.com
+44 020 3841 6445
Individuals in the EEA
We have appointed [insert full legal name] to be our data protection representative within the EEA. Their contact details are [insert full contact details].
Individuals within the EEA can contact us direct (see above) or contact our European representative.
Do you need extra help?
If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).
Terms of Use
About our terms
- These terms and conditions of use (Terms) explain how you may use this website and any of its content (Site). These Terms apply between Otherway London Limited (we, us or our) and you, the person accessing or using the Site (you or your).
- You should read these Terms carefully before using the Site. By using the Site or otherwise indicating your consent, you agree to be bound by these Terms. If you do not agree with any of these Terms, you should stop using the Site immediately.
- The Site is provided by us to you free of charge for information.
- If you would like these Terms in another format (for example: audio, large print, braille), please contact us using the contact details set out below.
About us
- We are Otherway London Limited (trading as Otherway, a company registered in England and Wales under company registration number 08064222. Our registered office is at 6th Floor, 9 Appold Street, London EC2A 2AP. Our VAT registration number is [154 527 508].
- If you have any questions about the Site, please contact us by:
a. sending an email to hello@otherway.com,
b. calling us on +44 (0)20 3841 6445 (our telephone lines are open Monday to Friday: 9.30 am to 6 pm).
Using the site
- The Site is for your personal and non-commercial use only.
- You agree that you are solely responsible for all costs and expenses you may incur in relation to your use of the Site.
- We make no promise that the Site is appropriate or available for use in locations outside of the UK. If you choose to access the Site from locations outside the UK, you acknowledge you do so at your own initiative and are responsible for compliance with local laws where they apply.
- We try to make the Site as accessible as possible. If you have any difficulties using the Site, please contact us using the contact details at the top of this page.
- As a condition of your use of the Site, you agree not to:
a. misuse or attack our Site by knowingly introducing viruses, trojans, worms, logic bombs or any other material which is malicious or technologically harmful (such as by way of a denial-of-service attack); We may prevent or suspend your access to the Site if you do not comply with these Terms or any applicable law.
b. attempt to gain unauthorised access to our Site, the server on which our Site is stored or any server, computer or database connected to our Site;
c. Use the Site for any purpose that is unlawful under any applicable law or prohibited by our Website Terms of Use ;
d. commit any act of fraud;
e. distribute viruses or malware or other similar harmful software code;
f. use the Site for purposes of promoting unsolicited advertising or sending spam;
g. to simulate communications from us or another service or entity in order to collect identity information, authentication credentials, or other information (‘phishing’);
h. use the Site in any manner that disrupts the operation of our Site or business or the website or business of any other entity;
i. use the Site in any manner that harms minors;
j. use the Site to promote any unlawful activity (including but not limited to the promotion or sale of any unlawful goods or services);
k. use the Site to represent or suggest that we endorse any other business, product or service unless we have separately agreed to do so in writing; or
l. use the Site to gain unauthorised access to or use of computers, data, systems, accounts or networks. - We may prevent or suspend your access to the Site if you do not comply with these Terms or any applicable law.
Your privacy and personal information
Your privacy and personal information are important to us. Any personal information that you provide to us will be dealt with in line with our Website Privacy Policy, which explains what personal information we collect from you, how and why we collect, store, use and share such information, your rights in relation to your personal information and how to contact us and supervisory authorities in the event you have a query or complaint about the use of your personal information.
Ownership, use and intellectual property rights
- The intellectual property rights in the Site and in any text, images, video, audio or other multimedia content, software or other information or material submitted to or accessible from the Site (Content) are owned by us and our licensors
- We and our licensors reserve all our intellectual property rights (including, but not limited to, all copyright, trade marks, domain names, design rights, database rights, patents and all other intellectual property rights of any kind) whether registered or unregistered anywhere in the world. This means, for example, that we remain owners of them and are free to use them as we see fit.
- Nothing in these Terms grants you any legal rights in the Site or the Content other than as necessary for you to access it. You agree not to adjust, try to circumvent or delete any notices contained on the Site or the Content (including any intellectual property notices) and in particular, in any digital rights or other security technology embedded or contained within the Site or the Content.
- The Otherway trade marks used on our Site belong to Otherway.. In some cases other trade marks and trade names may also be used on the Site or in the Content. Use by you of any trade marks on the Site or in the Content is strictly prohibited unless you have our prior written permission.
Submitting information to the site
- While we try to make sure that the Site is secure, we do not actively monitor or check whether information supplied to us through the Site is confidential, commercially sensitive or valuable.
- Other than any personal information which will be dealt with in accordance with our Website Privacy Policy, we do not guarantee that information supplied to us through the Site will be kept confidential and we may use it on an unrestricted and free-of-charge basis as we reasonably see fit.
Accuracy of information and availability of the site
- We try to make sure that the Site is accurate, up-to-date and free from bugs, but we cannot promise that it will be. Furthermore, we cannot promise that the Site will be fit or suitable for any purpose. Any reliance that you may place on the information on the Site is at your own risk.
- We may suspend or terminate access or operation of the Site at any time as we see fit.
- Any Content is provided for your general information purposes only and to inform you about us and our products and news, features, services and other websites that may be of interest, but has not been tailored to your specific requirements or circumstances. It does not constitute technical, financial or legal advice or any other type of advice and should not be relied on for any purposes. You should always use your own independent judgment when using our Site and its Content.
- While we try to make sure that the Site is available for your use, we do not promise that the Site will be available at all times or that your use of the Site will be uninterrupted.
Linking and framingsome text
- You may create a link to our Site from another website without our prior written consent provided no such link:some text
a. creates a frame or any other browser or border environment around the content of our Site;
b. implies that we endorse your products or services or any of the products or services of, or available through, the website on which you place a link to our Site;
c. displays any of the trade marks or logos used on our Site without our permission or that of the owner of such trade marks or logos; or
d. is placed on a website that itself breaches these Terms. - We reserve the right to require you to immediately remove any link to the Site at any time, and you shall immediately comply with any request by us to remove any such link.
Hyperlinks and third party sites
The Site may contain hyperlinks or references to third party advertising and websites other than the Site. Any such hyperlinks or references are provided for your convenience only. We have no control over third party advertising or websites and accept no legal responsibility for any content, material or information contained in them. The display of any hyperlink and reference to any third party advertising or website does not mean that we endorse that third party’s website, products or services. Your use of a third party site may be governed by the terms and conditions of that third-party site and is at your own risk.
Our responsibility to you
- If we breach these Terms or are negligent, we are liable to you for foreseeable loss or damage that you suffer as a result. By ‘foreseeable’ we mean that, at the time these Terms were formed, it was either clear that such loss or damage would occur or you and we both knew that it might reasonably occur, as a result of something we did (or failed to do).
- We are not liable to you for any loss or damage that was not foreseeable, any loss or damage not caused by our breach or negligence, or any business loss or damage.
- Nothing in these terms excludes or limits our liability for any death or personal injury caused by our negligence, liability for fraud or fraudulent misrepresentation, or any other liability that the law does not allow us to exclude or limit.
Events beyond our control
We are not liable to you if we fail to comply with these Terms because of circumstances beyond our reasonable control.
No third party rights
No one other than us or you has any right to enforce any of these Terms.
Complaints
- We will try to resolve any disputes with you quickly and efficiently. If you are unhappy with us, please contact us as soon as possible using the contact details set out at the top of this page.
- The laws of England and Wales apply to these Terms, although if you are resident elsewhere you will retain the benefit of any mandatory protections given to you by the laws of that country.
- Any disputes will be subject to the non-exclusive jurisdiction of the courts of England and Wales. This means that you can choose whether to bring a claim in the courts of England and Wales or in the courts of another part of the UK in which you live.
Variation
- These Terms were last published on [09.12.24] and last updated on [09.12.24].
- No changes to these Terms are valid or have any effect unless agreed by us in writing or made in accordance with this clause 16.
- We reserve the right to vary these Terms from time to time. Our updated Terms will be displayed on the Site and by continuing to use and access the Site following such changes, you agree to be bound by any variation made by us. It is your responsibility to check these Terms from time to time to verify such variations.