Stellar Omada Privacy Policy

At Stellar Omada we are committed to respect and protect your privacy in adherence to the General Data Protection Regulation (GDPR). This privacy policy explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. This Privacy Policy applies to all Stellar Omada activities.

Personal Data is information that can be used directly or indirectly to identify a living individual.  Personal Data may include special category information (sensitive data), such as information that reveals racial or ethnic origin, political opinions, religious beliefs, trade union membership, health or sexual orientation (Sensitive Personal Data). Stellar Omada does not collect or process any special categories of personal data, such as public unique
identifiers or sensitive personal data.

Stellar Omada is a UK based company with our offices located in Edinburgh. Our registered headquarters are Birchin Court, 20 Birchin Lane, London, England, EC3V 9DU
Stellar Omada is the data controller and our Information Security Team can be contacted at ISMT@Stellaruk.co.uk.

When do we collect personal data about you ?

● When you are using our services or products.
● When you interact with us in person, through correspondence, by phone, by social media, or through our websites.
● We may collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests. Before data is collected we make sure an assessment is made, ensuring that there is an established mutual interest between you and Stellar Omada.
● If you apply for a role at Stellar Omada.

Why do we collect and use personal data ?

We collect and use personal data mainly to perform direct sales, direct marketing and customer service. We also collect data about suppliers, partners and persons seeking a job or working in our company.

We may use your information for the following purposes:

● Send you marketing communications which you have requested. These may include information about our products and services, events, activities, and promotions of our associated partners’ products and services. This communication is subscription based and requires your consent.
● Send you information about the products and services that you have purchased from us.
● Perform direct sales activities in cases where legitimate and mutual interest is established.

● Reply to a ‘Contact me’ or other web forms you have completed on one of our websites.

● Follow up on customer support enquiries, emails, chats, or phone calls.
● Perform contractual obligations such as order confirmation, license details, invoice, reminders, and similar.
● Contact you to conduct surveys about your opinion on our products and services.
● Process a job application.

What type of personal data is collected ?

● We collect name, phone number, title and email address, in addition to your company’s name and contact information. We may also collect feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails. From our websites we may collect IP-address and actions taken on the site.
● If you apply for a job at Stellar Omada, we collect the data you provide during the application process including CVs, interview notes and onboarding process.

How we use your personal data ?

Personal data supplied by you will be used for the purposes specified in this policy.

We may use your personal information to:

● Perform tasks in relation to recruiting and hiring purposes
● Perform tasks and functions in accordance with our contractual obligations
● Respond to your specific queries and requests in the appropriate manner
● Send you general (non-marketing) commercial communications
● Send you any email notifications you have specifically requested
● Track and address service and quality issues
● Evaluate the performance of our services
● Comply with legal requirements

During the recruitment and hiring process, we use the personal data you provide to:

● Manage and process your application
● Communicate with you about the process, set up and conduct interviews and assessments
● Conduct background checks, as required or legally permitted by applicable local law
● Evidence to our clients candidate suitability (e.g. Financial Services screening)

For successful candidates we will use your personal data for onboarding, including to set up necessary business processes for your employment with Stellar Omada (and where required our clients), such as issuance of security ID, training, payroll, benefits, expense reimbursement, performance management, company email, access to company facilities, networks and systems (and/or the networks and systems of our client).

With your consent, if you are not hired for the first position to which you apply, we may retain and consider your data obtained through the application process for other vacancies within Stellar Omada. At all times, we will process your personal data fairly and lawfully. We will retain your personal data for as long as is necessary for the purposes stated above.

We may also receive personal data about you from our clients. In such cases, Stellar Omada processes personal data about you so that we can provide services for our clients as instructed by our clients and in accordance with our contractual obligations. Our clients are responsible for complying with
regulations or laws regarding notice, disclosure, and/or obtaining consent prior to transferring the data to Stellar Omada for processing purposes.

How long do we keep your personal data ?

Stellar Omada store personal data for as long as we find it necessary to fulfil the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.

This means that we may retain your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymised.

Your rights to your personal data
For your personal data, you may exercise the following rights:

● Access – You have the right to obtain confirmation from us if we are processing your personal data.
● Rectification – You have the right to request that we correct inaccurate personal data and to have incomplete data completed.
● Objection – You have the right to object to the processing of your personal data for compelling and legitimate reasons relating to your particular situation and we will comply except in cases where legal provisions expressly provide for that processing.
● Restriction – You may request to restrict processing of your personal data if:

o you contest the accuracy of the data – for a period we need to verify your request;
o the processing is unlawful and you oppose the erasure of the data and request restriction instead;
o we no longer need the data, but you tell us you need the data to establish, exercise or defend a legal claim; or
o you object to processing based on public or legitimate interest – for a period we need to verify your request.

● Erasure – You may request to erase your personal data where there is no compelling reason for its continued processing.
● Right to lodge a complaint – You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your
residence, place of employment, or the location where the issue that is the subject of the complaint occurred.
● Right to refuse or withdraw consent – Please note that in case we ask for your consent to processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your personal data that occurred prior to the withdrawal of your consent will not be affected.

You can exercise these rights by contacting us at ISMT@Stellaruk.co.uk.

If you consider that the way we process your personal data infringes your rights under the GDPR or is not compliant, you can lodge a complaint with
Stellar Omada directly or with a supervisory authority in the EU Member state in which you reside or where the data was processed.

Do we share your data with anyone ?

We do not share, sell, rent, or trade your information with any third parties without your consent, except from what is described below:

Third-party Service Providers working on our behalf:
We may pass your information on to our distributors, agents, sub-contractors and other associated organisations with the purpose of them providing services to you on our behalf.

If required by law:
We will disclose your personal information if required by law or if we, as a company, reasonably believe that disclosure is necessary to protect our company’s rights and/or to comply with a judicial proceeding, court order or legal process. However, we will do what we can to ensure that your privacy rights continue to be protected.

Use of sub-contractors (processors and sub-processors)
We may use sub-contractors to process personal data on our behalf, we are responsible for making sure they commit themselves to adhere to this Privacy Policy and applicable data protection legislation by signing a Data Processing Agreement.
If the sub-contractor processes Personal Data outside the EU/EEA area, such processing must be in accordance with the EU Privacy Shield Framework, EU Standard Contractual Clauses for transfer to third countries, or another specifically stated lawful basis for the transfer of personal data to a third country.

Updates To Our Privacy Statement
We may update, amend or remove this Privacy Statement from time to time without notice. The applicable version will always be available on our websites. When we update or amend this statement, we will also update the date at the bottom. Only the current statement is effective, so please review it periodically.

Effective 3rd December 2020