Publication date: 9 July 2024

Effective date: 1 September 2024
Previous Versions: 7 October 2023

Whether you use our websites or apps (“Platform”), speak to one of our team, use our products and services (“services”), are one of our suppliers or apply for a job, you are trusting us with your personal data. All references to “personal data” in this policy, means any data which identifies a natural person, or which allows that person to be identified when combined with other data.

This policy sets out how we collect, use and respect such personal data, and how the law protects you and your personal data.  If you do not accept and agree with this policy, you must stop using our Platform and services immediately.

Who are we?

We are One Plan Limited. Our business is registered in England with company number 11695518 and our registered address is 124 City Road, London, England, EC1V 2NX. Our websites are https://www.oneplan.io/ and https://www.venuetwin.com/, and associated sites and microsites.

If you have any questions about this privacy policy, including requests to exercise your legal rights, please contact us using the contact details below.

Why this policy exists?

This privacy policy:

• explains how we collect and process your personal data. Please read it together with any other data protection documents we may have sent you. This policy supplements other such documents and is not intended to override them.
• is provided in accordance with our obligations under applicable privacy and data protection law.
• is kept under regular review. This version of the policy became effective on the date shown above.
• may change from time to time and we will post the amended policy on the Platform.
• does not apply to any data you provide to us when we process personal data on your behalf as your data processor i.e. where we process customer data within the cloud service we provide to you, as a business to business service provider.

What personal data do we collect from you?

We collect and use personal data relevant to your use of our services, and your contact with us via our Platform, or through other means.

If you are enquiring about using our services, signing up to receive personal data from us, entering into a contract with us or if you are enquiring about employment opportunities, it may be necessary for you to provide certain data to us.

The data you provide or may provide is listed below. In this context, we are a data controller.   If we are a data controller in respect of your personal data, the statements in this policy apply.

We have set out below the personal data we may collect, use, store and transfer:

• Contact data including company name, billing address, delivery address, email address and telephone numbers.
• Billing and payment data including billing address, payment details, other invoicing details, transaction history, bank details, business accounts and taxation data, authorised user details, identification details or documents, and details of services supplied.
• Identity data including your name, username, marital status, title, date of birth, gender, and social media accounts (e.g. LinkedIn).
• Profile data including usernames and passwords, purchases or orders made, preferences.
• Online Usage Data, metadata and web information including:
  • Platform Metadata. When you use the Platform, metadata is generated to provide context of the use of the service including the path that you take through and from our Platform (including date and time), pages that you viewed or searched for, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
  • Technical data. Like most websites and services delivered over the Internet, our Platform servers automatically collect information when you access or use our Platform, recording this information in log files. This includes information about use of the Platform and services, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, screen resolution and other technical characteristics of your device, your use of our services and applications and connection to our Platform, and back ups of all other information referred to in this section of the policy.
• Marketing and communications data including preferences in receiving marketing from us and third parties and communication preferences.
• Organisation and Employment data including place of work, job title and organisation contact info; current and past employment, experience, qualifications, skills, interests, CVs, education details, and any other employment information disclosed by you.
• Correspondence: where you contact us for any reason (for example, requests for technical or operational support, where you have a question, or where you exercise your data protection rights), or where you respond to surveys or otherwise give us feedback, we will collect personal data contained in this correspondence.
• Cookies Data like many websites, we use ‘cookies’ to enhance your experience and gather information about visitors and visits to our websites. See ‘How we use cookies’ below for information about cookies and how we use them.

We also collect, use, and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your personal data but is not considered ‘personal data’ in law as it does not reveal your identity. For example, we may aggregate Online Usage Data, to calculate the percentage of users accessing a specific Platform feature.  However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we will apply this policy to such combined data.

Information relating to children

Our Platform and our services are not intended for children, and we do not knowingly collect personal data on children. If you believe that we have received personal data on someone under the age of 18, please contact us.

How do we collect personal data from you?

We use different methods to collect data including through:

• Information you provide to us directly. You may give us personal data, including details such as a name, email address and other contact details in person, or by creating an account or filling in forms on our Platform, or by corresponding with us by post, phone, email, social media and/or otherwise. This includes personal data provided when you:
  • contact us via our Platform (including using our AI planning expert ‘OneScout’ or a chatbot);
  • request our services;
  • meet with, contact, or engage with our staff;
  • subscribe to our publications or newsletters, or request any other personal data to be sent to you;
  • contact us about a role with us; or
  • respond to a survey, make a complaint or give us some feedback.
• Automated technologies or interactions. When you interact with our Platform, we may automatically collect technical data about your equipment, IP address, browsing actions and patterns. We collect this data by using cookies and other similar technologies. We may also receive technical data if you visit other websites employing our cookies.
• Third parties and publicly available sources. We may receive personal data from various third parties as set out below:
  • identity and contact data from other individuals at your organisation
  • personal data given to us by our customers, advertising networks, or other businesses that we work with
  • business partners, suppliers and sub-contractors
  • technical data from analytics providers (such as Google analytics), and/or search information providers;
  • employment, identity and contact data from recruitment agencies, previous employers, etc; and
  • publicly available sources

How we use cookies

Our Platform uses cookies and similar technologies to distinguish you from other users of our Platform. This helps us to provide you with a good experience when you use our Platform and allows us to improve our Platform. You can set your browser to refuse all or some browser cookies, but this may affect all or some of the functionality of our websites. For more information about the cookies we use, see our Cookie Policy.

Why we collect and use your personal data

We will only collect and use personal data when the law allows us to. Most commonly, we will use your personal data so we can provide our services, for marketing, and if required by law.

The table below set out the ways we use personal data and our legal basis for doing so.  Most commonly, we will use your personal data:

• where we need to perform the contract we are about to enter into or have entered into with you or otherwise provide a service to you;
• where it is in our legitimate interest to do so (or those of a third party) and it is proportionate to do so; or
• where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing personal data but exceptionally rely on consent to send marketing communications to you via telephone and/or email. You have the right to withdraw your consent at any time by responding to the person that contacts you and/or by contacting us.

Where we need to collect personal data by law, or under the terms of a contract and you do not provide that personal data when requested, we may not be able to perform the contract or provide you with our services.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another lawful reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so, or ask for your consent for us to process your data for this additional purpose.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

If you wish to get an explanation as to how we are processing your personal data which is not covered by this policy, please contact us.

Profiling

Profiling activities consist of using personal data of individuals to predict their interests and likely behaviours. This is usually carried out using behavioural information and, amongst other uses, helps us to inform our decisions about marketing audiences. This allows us to send the right message to the right audience.

We may use information generated when you use our Platform and services to improve them, and give you the best service and experience. This means that we may use information (including data collected using cookies and similar technologies) to evaluate and predict your personal preferences and interests. Please note that this is subject to your consent where required by applicable law.

We may conduct profiling activities to:

• support you and personalise the communications we send in relation to our Platform and services where permitted by applicable law and in line with your preferences;
• deliver advertising, marketing or information which may be useful to you, based on your use of our Platform and services (considering your preferences as required); and
• provide you with location-based services (for example location relevant content) where we collect geo-location data.

Please be aware that, in connection with the purposes above, we may use any  personal data of your customers, suppliers, employees, and other individuals, whose personal data you input into our Platform.

Who we share your personal data with & why?

Third parties

We may share your personal data with third parties, for the purposes of providing our services and running our business effectively. Most commonly, this includes online service providers, our IT service providers, those who manage our data, and our advisers and marketing partners.  We may have to share personal data with third parties for the purposes and activities set out above in Why we collect and use your personal data. These third parties include:

• Service providers who perform services and functions on our behalf in connection with the operation of our business such as software and application service providers, and third parties who host, store and manage the Platform and data, or who provide programming or technical support, etc.
• Payment processors.
• Professional advisers including our accountants, insurance brokers, banking support, legal advisors etc.
• Partners that provide research and analytics, analyse Platform traffic and understand customer needs and trends.
• Marketing service providers to help us to communicate with you, including  third parties where you have a relationship with that third party, such as social media providers, partners, and other third parties with which we work and whose products or services we think will interest you in the operation of your business activities.
• Parties that compel us to disclose your personal data by legal request, or, because we believe that such action is necessary), such as government or regulatory authorities.
• Those to whom we may sell, transfer, or merge parts of our business with, or where we acquire other businesses or merge with them. If such a change happens then any new owners may use your personal data in the same way as set out in this policy.

We require others to respect the personal data we share with them, and to only use it in ways the law allows.  We only allow others to use such personal data for the specific purposes we set out, and not for any other purposes.  When we engage processors to process personal data on our behalf, we ensure a contract is in place with the processor that sets out the details of the processing. We will take all reasonable steps to ensure that your personal data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of these third parties under applicable data protection legislation.

Except as set out above, we will only share personal data without notice to you if we, in good faith, believe that such action is necessary to:

• comply with legislation or any legal process served on us;
• protect and defend our rights and/or property; or
• to protect personal safety.

International transfers

Our services are global, and your personal data may be stored and processed in any country where we have operations, our staff are located or where we engage service providers involved in, among other things, the fulfilment of your order, the processing of your payment details or the provision of support services. This will involve a transfer of your personal data to countries outside of your country of residence, where data protection rules are different from those of your country of residence.

Processing of your personal data will involve a transfer of data to countries outside the European Economic Area, Switzerland or the UK. Whenever we transfer personal data outside the European Economic Area, Switzerland or the UK, we ensure a that appropriate measures and controls are in place to protect that data in accordance with applicable data protection laws.   In each case, such transfers are made in accordance with applicable data protection laws and may be based on the use of:

• the European Commission’s Standard Contractual Clauses for transfers of personal data outside the EEA
• the UK’s International Data Transfer Agreement and/or the European Commission’s Standard Contractual Clauses and/or the UK Addendum for transfers of personal data outside the UK.

For further details on transfer mechanisms, see the Information Commissioner’s Office website or the European Commission website.

Third-party links and services

Our Platform may include links to third-party websites and/or plug-ins. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or services and are not responsible for their privacy practices or privacy statements. When you leave our Platform, we encourage you to read the privacy policy of any new website you visit if this a concern for you.

What direct marketing do we conduct?

If you provide your contact details, we might contact you individually in the future if we think that our Services may be of interest to you.

If we think it appropriate, and where it is lawful for us to do so, we might also add you to our regular email marketing list.

You can ask us to remove your personal details from our marketing lists using the contact details listed at the end of this policy.

How we protect your personal data

We take steps to keep your personal data secure and we delete it when we no longer need it.

Security of your personal data 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those of our staff and other third parties who have a business need to know. They will only process personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Please note that this policy does not apply to other websites that you get to via a link from our Platform. We have no control over how your personal 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 personal data to them.

Data retention

We will retain personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of the personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally though:

• personal data we collect if you’re a customer is kept up to 6 years after you cease being a customer
• personal data we process for financial purposes (e.g. tax, VAT, etc.) is kept for 6 years plus the current year

We regularly review the information we hold, taking into account the lawful purpose for which we hold it, and any data that is deemed no-longer relevant or required is deleted where it is practicable to do so.

Your rights

Privacy laws give you certain rights.  For example, you can choose whether to receive marketing from us and you can ask us what personal data we have about you.

Opt Out Rights

You may, at any time opt-out of receiving marketing communications from us by contacting us or selecting the unsubscribe option in any e-mail from us.

Other Legal Rights

You have the right to:

• Request access. This means you can ask us to give you a copy of the personal data we hold about you, and to provide you with personal data about how we process it.
• Request correction. This means if we have incomplete or inaccurate personal data, you can ask us to correct it. It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data you provide us changes as our relationship evolves. Note, we may need to verify the accuracy of the new data you provide to us.
• Request erasure. This means you can ask us to delete or remove any personal data we have if there is no lawful reason for us continuing to have it. You also have the right to ask us to delete or remove personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing. This means you can contact us if you feel our use of your personal data impacts on your rights and freedoms. This applies if we are: (a) relying on our legitimate interest (or those of a third party) to use your personal data; (b) if we are using your personal data for direct marketing purposes; (c) if you believe we are using your personal data unlawfully; or (d) where we need to erase you personal data to comply with local laws. It is unlikely, but in some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
• Request restriction. This means you can ask us to suspend using your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer. This means you can ask us to transfer certain personal data we hold on you to you, or to a third party. We will provide to you, or the third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated personal data which you initially provided consent for us to use, or where we used the personal data to perform a contract with you.
• Withdraw consent. This means you can tell us that you no longer consent to our use of your personal data at any time where we are relying on consent as the legal basis to process your personal data. This action will also not affect the lawfulness of any processing carried out before you withdraw your consent.

What we may need from you

We may need to request specific personal data from you to help us confirm your identity and your rights in relation to your request. This is a security measure to ensure that personal data is not disclosed to any person who does not have a right to receive it. We may also contact you to ask you for further personal data in relation to your request to speed up our response.

No fee usually required

You will not have to pay a fee to exercise the rights listed above. However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Time limit to respond

We try to respond to all legitimate requests as soon as reasonably practicable and at least within one month. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Right to complain to the Personal data Commissioner’s Office 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

How to contact us

For general enquiries send us a message through the Platform: Contact – OnePlan Events.

If you have any questions or would like to contact us about this policy, you can contact our Data Protection Officer by email at: [email protected]

Changes to our privacy notice

We may change or update elements of this privacy policy from time to time or as required by law.