1.1 We are committed to safeguarding the privacy of onogo.com website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of onogo.com website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 Onogo.com incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via https://www.onogo.com/customer/account/index.
1.5 In this policy, "we", "us" and "our" refer to Decrescent Ltd t/a onogo.com.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of onogo.com and services ("usage data"). The usage data may include: 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. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving onogo.com.
2.3 We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is onogo.com. The account data may be processed for the purposes of operating onogo.com, providing our services, ensuring the security of onogo.com, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of onogo.com and business
2.4 We may process your information included in your personal profile on at onogo.com ("profile data"). The profile data may include your name, address, telephone number, email address, gender and date of birth. The profile data may be processed for the purposes of enabling and monitoring your use of onogo.com. The legal basis for this processing is our legitimate interests, namely the proper administration of onogo.com and business.
2.5 We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include name, email address, postal address, telephone number and date of birth. The source of the service data is onogo.com. The service data may be processed for the purposes of operating onogo.com, providing our services, ensuring the security of onogo.com, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.6 We may process information that you provide on onogo.com or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering onogo.com. The legal basis for this processing is our legitimate interests, namely the proper administration of onogo.com and business.
2.7 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you The legal basis for this processing is our legitimate interests, namely the proper administration of onogo.com and business
2.8 We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name & contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
2.9 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through onogo.com ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of onogo.com and business.
2.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.11 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Onogo.com will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of onogo.com and business and communications with users.
2.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence 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.
2.13 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.
2.14 In addition to the specific purposes for which we may process your personal data set out in this Section 2, 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.
2.15 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found at https://www.onogo.com/terms-and-conditions.
3.2 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 defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 We may disclose first name, last name, title, birthday, email address, telephone number, delivery address, billing address, purchase and order history, category preferences, brand preferences, contact with the Customer services Team, and any other information you provide during interacting with onogo.com to our service providers such as; marketing agencies, advertising partners, payment providers, fulfillment services and website hosts who help us run our business. Other entities that we may share your personal data with include; Law enforcement, credit reference agencies and fraud prevention agencies, so that we can help tackle fraud. Additionally; companies approved by you, such as social media Sites.
Personal data may be disclosed insofar as reasonably necessary for legitimate interests, namely the proper administration of onogo.com and business and the performance of a contract between you and us.
3.4 Financial transactions relating to onogo.com are handled by our payment services providers, Sage Pay Europe and PayPal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices here:
3.6 In addition to the specific disclosures of personal data set out in this Section 3, 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 defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our service providers. Such staff may be engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services.
When we, or our permitted third parties, transfer your information outside the European Economic Area, we or they will impose obligations on the recipients of that data to protect your information to the standard required in the EEA or otherwise require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we will put in place appropriate safeguards to ensure that your information remains adequately protected.
4.5 You acknowledge that personal data that you submit for publication through onogo.com or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 5 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.
5.2 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.
5.3 We will keep your information for as long as you have your account, or as long as is needed to be able to provide the services to you, or (in the case of any contact you may have with our Customer Care Team) for as long as is necessary to provide support-related reporting and trend analysis only.
5.5 Notwithstanding the other provisions of this Section 5, we may 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.
6.1 We may update this policy from time to time by publishing a new version on onogo.com.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of significant changes to this policy by email.
7. Your rights
7.1 In this Section 7, we have summarised 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.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 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. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting: https://www.onogo.com/customer/account/index/ when logged into onogo.com.
7.4 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.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 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. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 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. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us: Decresecent t/a Onogo.com, Unit 2A, St Peter's Technical Park, St Peter, Jersey, JE3 7ZN or by email to email@example.com addition to the other methods specified in this Section 7.
8. About cookies
8.1 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.
8.2 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.
8.3 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.
9. Cookies that we use
For the exhaustive list of cookies we collect see the List of cookies we collect section.
10. Cookies used by our service providers
11. Managing cookies
11.1 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:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on onogo.com.
12. Our details
12.1 This website is owned and operated by Decrescent ltd t/a onogo.com
12.2 We are registered in Jersey, Channel Islands under registration number 100561 and our registered office is at Unit 2a, St Peters Technical Park, St. Peters, Jersey, JE37ZN.
12.3 Our principal place of business is at Unit 2a, St Peters Technical Park, St. Peters, Jersey, JE37ZN.
12.4 You can contact us:
(a) By post, to the postal address given above
(b) using onogo.com contact form here https://www.onogo.com/customer-service
(c) by telephone on 0800 292 2785 or
(d) by email, using firstname.lastname@example.org
13. Data protection officer
13.1 Our data protection officer's contact (William Edingborough) Will@onogo.com.
The table below lists the cookies we collect and what information they store.
|COOKIE name||COOKIE Description|
|CART||The association with your shopping cart.|
|CATEGORY_INFO||Stores the category info on the page, that allows to display pages more quickly.|
|COMPARE||The items that you have in the Compare Products list.|
|CURRENCY||Your preferred currency|
|CUSTOMER||An encrypted version of your customer id with the store.|
|CUSTOMER_AUTH||An indicator if you are currently logged into the store.|
|CUSTOMER_INFO||An encrypted version of the customer group you belong to.|
|CUSTOMER_SEGMENT_IDS||Stores the Customer Segment ID|
|EXTERNAL_NO_CACHE||A flag, which indicates whether caching is disabled or not.|
|FRONTEND||You sesssion ID on the server.|
|GUEST-VIEW||Allows guests to edit their orders.|
|LAST_CATEGORY||The last category you visited.|
|LAST_PRODUCT||The most recent product you have viewed.|
|NEWMESSAGE||Indicates whether a new message has been received.|
|NO_CACHE||Indicates whether it is allowed to use cache.|
|PERSISTENT_SHOPPING_CART||A link to information about your cart and viewing history if you have asked the site.|
|RECENTLYCOMPARED||The items that you have recently compared.|
|STF||Information on products you have emailed to friends.|
|STORE||The store view or language you have selected.|
|VIEWED_PRODUCT_IDS||The products that you have recently viewed.|
|WISHLIST||An encrypted list of products added to your Wishlist.|
|WISHLIST_CNT||The number of items in your Wishlist.|
|_cfduid||Used to identify trusted web traffic.|
|PHPSESSID||Preserves user session state across page requests .|
|frontend_cid||onogo.com uses Magento to provide its web store and allow customers to place orders. This cookie is used to handle user sessions during their visits.|
|t_listname||Monitor site usage to enable improvement of user experience.|
|shipping_region||Ensures display of site content relevant to user location.|
|sentisum_session||Monitor site usage to enable improvement of user experience.|
|mailchimp_landing_page||Monitors visitor activity from email marketing.|
|_hjDonePolls||Remembers if user has previously responded to a certain form|
|_hjIncludedInSample||Determines if the user navigation should be registered in a certain statistical place holder.|
|ads/ga-audiences||Used by Google Adwords to re-engage visitors based on online behavior across websites.|
|Collect||Used to send data to Google Adwords about visitors device & behavior, tracks visitors across devices and marketing channels|
|Fr||Used by facebook to deliver advertisement products from third party advertisers.|
|NID||Registers a Unique ID that identifies a returning users device for targeted advertising.|
|tr||Facebook tracking pixel tracks conversions from Facebook ads, improve ads future ad relevance to qualified lead|
|@@History/@@scroll|#||Helps onogo.com understand how users interact with the site - Unclassified.|
|_ga||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.|
|_gat||Used by Google Analytics to throttle request rate.|
|_gid||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.|
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