Welcome to R.O.EYE’s privacy policy.
R.O.EYE Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy aims to give you information on how R.O.EYE Limited collects and processes your personal data through your use of this website and its SingleView tracking platform. SingleView consists of a number of components – a tracking platform to gather the data, databases to store the data and the software to process the data.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
R.O.EYE is the controller and responsible for your personal data (referred to as R.O.EYE, “we”, “us” or “our” in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal right, please contact the DPO using the details set out below.
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: R.O.EYE Limited
Email address: gdpr@roeye.com
Postal address: 3rd Floor, 54 Princess Street, Manchester, M1 6HS
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.
We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. 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 and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We collect data when our tracking pixel fires. This pixel fires once on each initial website entry event (it does not fire during in-site navigation). The pixel also fires on the conversion event, ie an Ecommerce Sale.
Details of the exact data we collect are detailed in the table below:
| Field | Description | Example |
|---|---|---|
| Visit ID | A randomly generated, anonymous alpha-numeric string | 9217c29e-4f6a-4c0b-8615-7b8866b7f85f |
| Timestamp | The timestamp the event occurred | 2018-01-27 17:34:59+00 |
| Client Site Name | The name of the website visited | SiteName |
| Referrer URL | The full URL of the referring click | https://www.google.co.uk |
| Landing URL | The full URL of the page on the client’s website that the visitor arrived on | https://clientsite.com/offers |
Additional information captured during a conversion event
| Order ID | The client’s unique order id for the purchase | 0297382 |
| Order Amount | The purchase amount | 23.99 |
There may also be additional meta information passed through at conversion, as agreed with the client on a case by case basis, for example voucher code.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We drop a cookie when a visitor lands on an authorised client’s website. This cookie will be a first-party cookie in relation to the client’s domain and will be governed by the client’s own website terms and conditions.
We may drop a cookie when an ad is served via a third-party advertising network. This cookie contains a random, anonymous alpha-numeric string.
We use this cookie to understand the success of different advertising campaigns.
We also collect a small amount of data. This includes the time the ad was served, the page on which the ad appeared, and the user-agent string.
For more information about the cookies that we use, see below.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
See the ‘Glossary’ below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer |
(a) Identity (b) Contact |
Performance of a contract with you |
| To process and deliver your service |
(a) Identity (b) Contact (c) Marketing and Communications |
Performance of a contract with you |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services) |
| To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our services and grow our business) |
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
We use the following cookies:
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
| Cookie Title Cookie Name |
Purpose | More Information |
|---|---|---|
|
Google Analytics _ga _gat _gid |
This cookie enables us to: Estimate our audience size and usage pattern Recognise you when you return to our site |
https://developers.google.com/analytics/ devguides/collection/analyticsjs/cookie-usage |
|
AWS AWSELB AWSELBCORS |
This cookie is essential for our site. It allows the load balancer to correctly balance traffic loads to our servers. | https://docs.aws.amazon.com/elasticloadbalancing/ latest/classic/elb-sticky-sessions.htm |
We do not share the information collected by the cookies with any third parties.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Except for essential cookies, all cookies will expire after 2 years.
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 reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
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.
We may share your personal data with the parties set out below for the purposes set out in the table above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your 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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
If we have a contract with you, typically we retain your personal data until that contract terminates.
In some circumstances you can ask us to delete your data: see ‘Your Legal Rights’ below for further information.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month 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.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.