1. Who we are

1.1. This privacy notice (the “Privacy Notice”) applies to all personal information processing activities carried out by Origami Engineering Ltd (“Origami”).
1.2. Origami is a data controller with regards to the personal data that we process in the course of carrying out our business (including the products and services that we provide). In this Privacy Notice, references to “we”, “us” or “our” are references to Origami.
1.3. Our registered business address is Minster House, 42 Mincing Ln., London EC3R 7AE and our contact details can be found at origamiengineering.net
1.4. We respect individuals’ rights to privacy and the protection of personal data. This Privacy Notice outlines how we collect and use personal data in the course of carrying out our business. “Personal data” is any information relating to an identified or identifiable living person. We may update this Privacy Notice from time to time. When we do we will communicate any changes to you and make the updated Privacy Notice available.

 

2. The data we process

2.1. We collect, handle, store, disclose, and otherwise use (“process”) various categories of personal data at the inception, and for the duration, of your relationship with us. We will limit the collection and use of your personal data to that which is necessary for carrying out one or more legitimate purposes, as outlined in this notice. Personal data may include:
    2.1.1. basic personal information, including name, address, and date of birth;
    2.1.2. contact details;
    2.1.3. individual tax identifier;
    2.1.4. information about your education and employment;
    2.1.5. recordings of phone conversations; and
    2.1.6. shareholdings of products managed by Origami.
2.2. We do not normally process special categories of personal data. Any processing of special categories of personal data will only take place once we’ve obtained your explicit consent, or are otherwise lawfully permitted to do so (and then only for the particular purposes and activities set out at Schedule A for which the information is provided). Special categories of personal data include:
    2.2.1. information about racial or ethnic origin;
    2.2.2. religious or philosophical beliefs;
    2.2.3. trade union membership;
    2.2.4. physical or psychological health details or medical conditions; and
    2.2.5. biometric information, relating to the physical, physiological or behavioral characteristics of a person.
2.3. Where permitted by law, we may process information about criminal convictions or offenses and alleged offenses for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with the law relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions.

 

3. How we obtain data

3.1. Your data is made up of all the personal data we collect and hold about you. It includes:
    3.1.1. data you give to us;
    3.1.2. data that we receive from third parties – including third parties who provide services to us such as carrying out Know Your Customer Due Diligence; and
    3.1.3. data that we gather from publically available sources, such as company websites and online search engines.

 

4. Your rights

4.1. We want to ensure that you are aware of your rights in relation to your personal data that we process. These rights, and the circumstances in which they apply are set out in the table below. 
4.2. Should you wish to exercise any of these rights, have any questions about how we use your personal data that are not answered in this Privacy Notice, or would like to make a complaint, please contact us at dataprotection@origamiengineering.net or 0207 097 3810. Overseas number: +44 207 097 3810.
4.3. Please note that in some circumstances, if you do not agree to the way we use your data, we may no longer be able to provide certain products and/or services to you.

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5. Changes to the way we use your information

5.1. We may change the way we process your data from time to time. Where we believe you may not reasonably expect such changes, we will inform you and allow a period of at least 30 days for you to make any objections before the alteration is made. 
However please note that in some cases, if you do not agree to such changes it may not be possible for us to continue to deliver certain services and/or products we provide to you.

 

6. Sharing with third parties

6.1. We will not share your information with anyone outside Origami except:
    6.1.1. where we have your consent;
    6.1.2. where required for your product or service;
    6.1.3. where we are required by law and by law enforcement agencies, judicial bodies,     government entities, tax authorities or regulatory bodies around the world;
    6.1.4. with third parties providing services to us, such as due diligence; or
    6.1.5. where it is permitted by law, it is necessary for our legitimate interests or those of a third     party, and it is not inconsistent with the purposes listed above.
6.2. Origami will not share your data with third parties for their own marketing purposes without your prior consent.

 

7. Transferring information overseas

7.1. We may transfer your data to organisations in other countries on the basis that anyone to whom we pass it protects it in the same way we would and in accordance with applicable laws.
7.2. In the event that we transfer information to countries outside of the European Economic Areas (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway), we will only do so where our Compliance Department has confirmed that at least one of the following is in place:
    7.2.1. the European Commission has decided that the country or the organisation we are sharing     your information with will protect your information adequately;
    7.2.2. the transfer has been authorised by the ICO;
    7.2.3. we have entered into a contract with the organisation with which we are sharing your data     (on terms approved by the European Commission) to ensure your information is adequately     protected (if you wish to obtain a copy of the relevant data protection clauses, please contact us     on 0207 097 3810. Overseas number: +44 207 097 3810);
    7.2.4. the transfer is required for us to meet our contractual or pre-contractual obligations with     you;
    7.2.5. the transfer is needed to complete a contract with a Third Party in your interest;
    7.2.6. a matter of important public interest;
    7.2.7. the transfer is necessary for the establishment, exercise or defence of legal claims;
    7.2.8. we’re protecting your vital interests; and/or
    7.2.9. you provide your explicit consent to the proposed transfer, after having been informed of     the possible risks of such transfers due to the absence of adequate safeguards.

8. Marketing Information

8.1. Unless you have told us that you do not want to hear from us, we will send you relevant marketing information by mail, phone, e-mail, text and other forms of electronic communication. If you change your mind about how you would like us to contact you or you no longer wish to receive this information, you can tell us at any time by contacting us at dataprotection@origamiengineering.net or 0207 097 3810. Overseas number:  +44 207 097 3810.

 

9. How long we keep your information

9.1. In the course of our relationship with you, we will create and store records of your personal data on a variety of media (physical or electronic) and formats.
9.2. We maintain these records in order carry out our business effectively (for example, for operational reasons such as dealing with any queries relating to your relationship with us) and to comply with legal and regulatory requirements.
9.3. Retention periods for records are determined based on the type of record and the applicable legal or regulatory requirements.
9.4. We normally keep records for up to six years after your relationship with us ends.
9.5. We may on exception retain your data for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that Origami will be able to produce records as evidence if they are needed.
9.6. Retention periods may change from time to time based on business or legal and regulatory requirements.
9.7. If you would like more information about how long we keep your information, please contact us at dataprotection@origamiengineering.net or 0207 097 3810. Overseas number: +44 207 097 3810.

 

10. Security

10.1. We have in place appropriate technical and organisational safeguards to protect against unauthorised or unlawful use of personal data, and against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data. 
10.2. However please be advised that we cannot eliminate security risks associated with the storage and transmission of Personal Data.