Effective Date May 24rd, 2018
Photon Orgone is committing to disclosing our information practices and implementing appropriate protections for any information that we collect or our users share with us. (Please refer to Section 1 below for types and definitions of information.) We are based in the United Kingdom. We store information about users of our Services on servers located in the United Kingdom. We may also store such information on servers and equipment in other countries.
Our Services, including any software used, collect both personal, non-personal and other information, about you and the computer system you use ("User System") as described below.
We are a company registered in the United Kingdom with registration number 11280148, and with our registered address as set out below.
- Email: firstname.lastname@example.org
- Post: Photon Orgone, 11 Fairstone Hill, Oadby, Leicester, LE25RL.
You must be 15 years of age or older to access or use our Services. We do not knowingly collect or maintain the personal information of children under the age of 15. Anyone under the age of 15 is not permitted to access or use the Services and must not attempt to register an account or submit any personal information to us. We will take appropriate steps to delete the personal information of persons under the age of 15.
- Types of personal information and other data collected.
1.1 Information that you provide to us.
1.1.1 We will collect any information that you provide to us when you:
- make an enquiry, provide feedback or make a complaint over the phone, by email or on our websites;
- submit correspondence to us by post, email or via our websites;
- submit a customer service request by raising a ticket;
- order products or services from our websites;
- create an account to use the websites;
- apply to be a Photon Orgone Affiliate;
- update your profile and other account details;
- subscribe to our newsletter and mailing lists;
- fill in a form, conduct a search, post content on the websites, respond to surveys, participate in promotions or use any other features of the websites;
- submit reviews, comments and posts on the websites (e.g. on the Photon Orgone blog);
- contact other users on the websites;
- register to and/or attend our events;
- submit a resume, an application to a job vacancy or attend an interview or assessment;
- submit an application to join the Photon Orgone affiliate program; and
- ‘follow’, ‘like’, post to or interact with our social media accounts, including Facebook, LinkedIn, Twitter, Instagram, YouTube, Twitch, Steam, Reddit, Discord, and Google+.
1.1.2 The information you provide to us will include (depending on the circumstances):
- Identity and contact data. Title, names, addresses, email addresses and phone numbers.
- Account registration data. Certain services may require that you register for an account. If you’re registering for an account you may also provide a username, password, date of birth, address, phone number and credit card information. If you choose to login through a social media account, for instance Facebook, Twitter, Google+ or Disqus, we will collect certain public information about the social media account you log in with, which will be notified at the time you grant permission to login through the account.
- Transactional data. We will collect information related to your transactions on the websites, including the products and services you have ordered, any customization requirements, the date and time, the amounts charged and other related transaction details.
- Financial Data. If you are using the websites to purchase products or services, you will also provide payment details, which may include billing addresses, credit/debit card details and bank account details.
- Photos. If you choose to share photos with us, for example, images to be used on our Build Gallery page, then you may provide personal information in the form of photos of you or other people.
- Feedback and reviews. If you post on our websites, then you will provide details of any personal data that you share in the post, for instance, your username, your opinions, your experiences etc.
- Employment and background data. If you are submitting a job application, you may provide information about your CV, cover letter, work availability dates, desired pay level, a link to your website/blog/portfolio, a link to your LinkedIn profile, you academic and work history, qualifications, skills, projects and research that you are involved in, answers to specific questions we ask in relation to the role you are applying for, references, proof of your entitlement to work (e.g. passport and visa), your national security number, drivers license, other identity document details, and any other such similar information that you may provide to us.
- Survey data. from time to time we might ask if you would be willing to participate in our surveys; if you agree, we will also collect any information that you provide as part of that survey.
- Technical and system-related data. In relation to your use of our services or interactions with us, we will collect information such as your region, the specification and components of your PC, your chosen language and IP address.
1.1.3 Information we collect about you: When you access or use our Services, we may collect personal information about you. This can include traditional identifiers such as name, address, e-mail address, telephone number and non-traditional identifiers such as unique device identifiers and Internet Protocol (IP) addresses. We may collect personal information, and non-personal and other information that you or others give us, or allow us to receive either through preferences settings in your computer, device, or browser, from third parties such as social networks, or through the use of our Services (e.g. the pages you visit or the elements of our Services you use). The following are examples of the categories and types of personal information, non-personal and other information we may collect.
- Information contained in correspondence. We will collect any information contained in any correspondence between us. For example, if you contact us using a form on our websites, by raising a ticket for customer service, by email or telephone, we may keep a record of that correspondence;
- Information transmitted on the websites. We will collect information that you upload or post to your website account and/or any correspondence or interactions that you may have with other website users, for instance, if you comment on our blogs and have discussions with other Photon Orgone users on the website.
- Website usage data. We will collect information about your interactions with the websites, including information such as login data, IP address, page views, searches, requests, orders, pre-approvals, confirmations, agreements between you and other website users and other actions on the websites.
- Technical data. We will also collect certain information about how you use our websites and the device that you use to access our websites, even where you have not created an account or logged in. This might include your geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), the data transmitted by your browser (such as your IP address, date and type of the request, content of the request regarding the specific site, time zone settings, access status/HTTP status code, volume of data transmitted, browser type and version, language settings, time zone settings referral source, length of visit to the websites, date and time of the request, operating system and interface) number of page views, the search queries you make on the websites and similar information. This information may be collected by a third-party website analytics service provider on our behalf and/or may be collected using cookies or similar technologies. For more information on cookies please read the COOKIES section below.
1.1.4 Information we receive from third parties. In certain circumstances, we will receive information about you from third parties. For example:
- Users of our Service. We may receive personal information from other users of our Service, including website users, who may be based inside or outside the EU, for example information that is posted or uploaded by other users (e.g. reviews, comments), information relating to transactions and/or correspondence between website users.
- Photon Orgone Affiliates. We may receive personal information from Photon Orgone Affiliates, such as details of sales referrals.
- Third party retailers. We sell some of our products through third party retailers. We may receive personal information in relation to transactions made through these retailers, such as details of orders, returns and refunds requested.
- Marketing partners. We might also receive information about you from third parties if you have indicated to such third party that you would like to hear from us.
- Employers, recruitment agencies and referees. If you are a job applicant we may contact your recruiter, current and former employers and/or referees, who may be based inside or outside the EU, to provide information about you and your application.
- Service providers. We may collect personal information from our website developer, IT support provider, payment services provider, and HR and recruitment service provider (BambooHR) (who may be based inside or outside the EU).
- Fraud detection agencies. Where permitted or required by law, we may receive information about you, including demographic data or fraud detection information from third party service providers and/or partners who are based inside and outside the EU.
- Website and Service security. We will collect information from our website security service partners who are based outside the EU, about any misuse to the website, for instance, the introduction of viruses, Trojans, worms, logic bombs, website attacks or any other material or action that is malicious or harmful.
- Social media plugins. We currently use social media plugins from the following service providers who are based both inside and outside the EU: Facebook, Google+, Twitter, and LinkedIn. By providing your social media account details you are authorizing that third-party provider to share with us certain information about you.
- Publicly available sources. We currently use publicly available sources such as LinkedIn, publicly available websites and online portfolios, for instance to carry out identity and compliance checks.
- If you access our Services from a third party service such as the Apple App Store, Google Play, Amazon App Store, or another third party site or service (“TPS”), you are subject to the privacy policies of the respective TPS.
2. Information Use
2.1 We will use your information for the purposes listed below either on the basis of:
2.1.1 performance of your contract with us and the provision of our services to you;
2.1.2 your consent (where we request it);
2.1.3 where we need to comply with a legal or regulatory obligation; or
2.1.4 our legitimate interests or those of a third party (see section 2.4 below).
2.2 We use personal information and other data collected for the following purposes:
2.2.1 To communicate with you when you contact us, submit enquiries or provide feedback, or to contact you directly about products or services you have ordered (on the basis of our legitimate interest in communicating with users and customers)
2.2.2 To provide you with access to our websites in a manner convenient and optimal and with personalised content relevant to you including sharing your information with our website hosts and developers (on the basis of our legitimate interest to ensure our websites are presented in an effective and optimal manner).
2.2.3 To create and maintain your accounts and allow access to our Services (on the basis of performing our contract with you).
2.2.4 Certain parts of the Service enable you to communicate with each other, e.g. on our blog pages. We will use the information you have provided (such as your name and contact details) to enable you to communicate with each other (on the basis of our contract with you).
2.2.5 To process and facilitate transactions and payments, and to collect and recover money owed to us (on the basis of performing our contract with you and on the basis of our legitimate interest to recover debts due).
2.2.6 To provide technical customer support and respond to user inquiries (on the basis of our contract with you or on the basis of our legitimate interests to provide you with customer service), to deal with enquiries or complaints about the Service and share your information with our website developer, IT support provider, and payment services provider as necessary to provide customer support (on the basis of our legitimate interest in providing the correct products and services to our Service users and to comply with our legal obligations).
2.2.8 Solicit input and feedback to improve our products and services and customize your user experience (on the basis of our legitimate interest in providing the right kinds of products and services to our customers).
2.2.9 Where relevant (e.g. where you are an Photon Orgone Affiliate, or one of our partners/collaborators, to contact you and manage and facilitate our business relationship with you and your employer (on the basis of performing our contract with you and our legitimate interest in developing our business relationship).
2.2.10 To enable you to take part in prize draws, competitions and surveys (on the basis of performing our contract with you and our legitimate interest in studying how our websites and services are used, to develop them and grow our business).
2.2.11 To process any job applications you submit to us, whether directly or via an agent or recruiter including sharing this with our third party recruitment agency (on the basis of our legitimate interest to recruit new employees or contractors).
2.2.12 To keep in contact with you about our news, events, new Service features, and products or services that we believe may interest you, provided that we have the requisite permission to do so, and sharing your information with our marketing services provider (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so).
2.2.13 To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (on the basis of our legitimate interests in studying how our websites/services are used, to develop them, to grow our business and to inform our marketing strategy).
2.2.14 To make suggestions and recommendations and share your information with selected third parties such as suppliers and partners, to enable them to contact you with information about things that may interest you (where we have your consent to do so).
2.2.15 To interact with users on social media platforms including Facebook, LinkedIn, Twitter, Instagram, YouTube, Twitch, Steam, Reddit, Discord, and Google+ and, for example, responding to comments and messages, posting, ‘retweeting’ and ‘liking’ posts (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals).
2.2.16 To carry out aggregated and anonymised research about general engagement with our websites (on the basis of our legitimate interest in providing the right kinds of products and services to our website users).
2.2.17 To use data analytics to improve our Service and products, marketing, customer relationships and experiences (on the basis of our legitimate interests in defining types of customers for our websites and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy).
2.4 As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own or those of third parties. Where we refer to using your information on the basis of our “legitimate interests”, we mean our legitimate business interests in conducting and managing our business and our relationship with you, including the legitimate interests we have identified in section 2.2.
2.5 Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details of “Your Rights” in section 5 below.
2.6 Special category information: “special categories” of particularly sensitive personal information (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) and information about criminal convictions and offences requires higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We process special categories of personal information:
2.6.1 in limited circumstances, with your explicit written consent;
2.6.2 where we need to carry out our legal obligations or exercise rights in connection with employment;
2.6.3 where it is needed for reasons of substantial public interest, such as for equal opportunities monitoring;
2.6.4 where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent; or
2.6.5 where you have already made the information public.
3. Information Sharing and Disclosure
3.1 In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we will share your personal information when relevant with third parties such as:
3.1.1 Service users. Other users of our Service who you communicate with, who may be based both inside and outside the EU.
3.1.2 Photon Orgone Affiliates. Who may be based both inside and outside the EU.
3.1.3 Our service providers. Service providers we work with to deliver our business, who are acting as processors and provide us with:
- website development and hosting services based in the United Kingdom
- IT, system administration and security services based in the United Kingdom
- marketing and advertising services (including the Google AdWords service), analytics providers (including Google Analytics) based in the UK;
- maps services (including Google Maps API), based in the UK;
- social media plugin services including Facebook, Google+, Twitter, and LinkedIn based in the UK;'
- payment services based in the UK;
- identity verification, fraud prevention and detection services based in the USA;
- banking services based in UK
- legal, accountancy, auditing and insurance services and other professional advisers based in the UK,
- recruitment service providers based in the UK
3.1.5 Marketing parties. Any selected third party that you consent to our sharing your information with for marketing purposes;
3.1.6 Prospective sellers and buyers of our business. Any prospective seller or buyer of such business or assets, only in the event that we decide to sell or buy any business or assets; and
3.1.7 Other third parties (including professional advisers). Any other third parties (including legal or other advisors, regulatory authorities, courts, law enforcement agencies and government agencies) based in the USA, the United Kingdom and Germany where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.
3.2 We require third parties to maintain appropriate security to protect your information from unauthorised access or processing.
4. Cookies and Tracking Technologies.
4.1 We use standard tracking technologies like cookies, pixels and local storage, to collect certain types of personal and non-personal information, including: (i) which of our web pages, apps and other Services you access; (ii) information about your mobile device (such as device and browser type); and (iii) your Internet protocol address, search query and other information relating to your use of our websites. We collect these types of information to help us provide you a more personalized and relevant online experience including by remembering your preferences and providing personalized content.
The names of the cookies used on our websites and the purposes for which these cookies are used are set out in the table below:
Logged in user reference object
Expires when session is ended with browser close
5. Your rights to the information we hold about you
5.1 You have certain rights in respect of the information that we hold about you, including:
5.1.2 the right to ask us not to process your personal data for marketing purposes;
5.1.3 the right to request access to the information that we hold about you;
5.1.4 the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
5.1.6 the right to object to our using your information on the basis of our legitimate interests (refer to section 2.2 above to see when we are relying on our legitimate interests) (or those of a third party)) and there is something about your particular situation which makes you want to object to processing on this ground;
5.1.7 the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format, in certain circumstances;
5.1.8 in certain circumstances, the right to ask us to limit or cease processing or erase information we hold about you; and
5.1.9 the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) as well as a right to lodge a complaint with the relevant authority in your country of work or residence.
Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications relating to your user account even when you have requested not to receive marketing communications.
5.2 How to exercise your rights
5.2.1 You may exercise your rights above by contacting us at email@example.com, or in the case of preventing processing for marketing activities also by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in marketing, using the unsubscribe link at the bottom of the email.
5.2.2 If you have already registered an account, you may cancel any Account registered to you at any time by submitting a support ticket via our support site.
5.3 What we need from you to process your requests
5.3.1 We may need to request specific information from you to help us confirm your identity and to enable you 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.
5.3.2 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 may refuse to comply with your request in these circumstances. We will try to respond to all legitimate requests within one month. Occasionally it may 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.
6. Data Usage - how we look after your data and how long we keep it for
6.1 At Photon Orgone, we are always mindful of the data we collect and looking for ways to communicate better to our users why we need it and how we use it. We use data to improve your experience while using our products, such as storing your preferences and settings when you use our software. We also use data to determine what type of hardware you have and what games you play so that we can do things like offering recommendations for improving the performance of your system or reducing noise. We never sell your data or share it with third parties for any purpose.
6.2 We operate a policy of “privacy by design” by looking for opportunities to minimise the amount of personal information we hold about you. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:
6.2.1 ensuring the digital security of our websites by employing certificated Transport Layer Security (TLS) encryption;
6.2.2 ensuring the physical security of our offices, warehouses or other sites;
6.2.3 ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;
6.2.4 maintaining a data protection policy for, and delivering data protection training to, our employees; and
6.2.5 limiting access to your personal information to those in our company who need to use it in the course of their work.
While we take precautions against possible security breaches, no data transmission over the Internet is 100% secure, so we can’t guarantee security, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur.
6.3 We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for the purposes of exercising our legal rights or where we are permitted to do. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it. For example,
6.3.1 we archive our email and paper correspondence regularly and destroy information older than one year;
6.3.2 we retain information relating to orders, refunds and website user queries until it needs to be updated or deleted;
6.3.3 we maintain a suppression list of email addresses of individuals who no longer wish to be contacted by us. So that we can comply with their wishes we must store this information permanently; and
6.3.4 We retain historical data for approximately one year unless noted otherwise in the sections below. The types of data that we currently collect include:
Sign up date
We use this data to secure your account, to identify the data that is associated with it, such as your settings and hardware configuration, and to enable you to only have to sign-in once while using our sites. We also use this data to analyze engagement to help determine how we can improve the usage of our products.
Guest mode applies to users who have not registered and thus do not have accounts. We minimize the amount of data we collect to include only login times and the system profile information described in the previous section. On average about 1 kbyte of login data and 1.7 kbytes of system profile data is collected per month per guest user. This information helps us troubleshoot any problems you may experience while using our products.
7. Help keep your information safe
7.1 We urge you to take steps to keep your personal information safe (including your account password), and to logout of your account after use. If your TPS account is hacked, this may lead to unauthorized access, so be careful to keep your account information secure. You can also play a part in keeping your information safe by:
7.1.1 choosing a strong account password and changing it regularly;
7.1.2 using different passwords for different online accounts;
7.1.3 keeping your login and password confidential and avoiding sharing these details with others;
7.1.4 making sure you log out of the website each time you have finished using it. This is particularly important when using a shared computer;
7.1.5 letting us know if you know or suspect that your account has been compromised, or if someone has accessed your account without your permission;
7.1.6 keeping your devices protected by using the latest version of your operating system and maintaining any necessary anti-virus software; and
7.1.7 being vigilant to any fraudulent emails that may appear to be from us. Any emails that we send will come from an email address ending in ‘@photonorgone.co.uk’.
8. International transfers of your information
8.1 Our company is located in the UK.
8.2 [We share your personal data within the Photon Orgone Group (Photon Orgone Ltd.
8.3 Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
8.4 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 transfer solutions are implemented:
8.4.1 We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
8.4.2 Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, European Commission: Model contracts for the transfer of personal data to third countries; and
8.4.3 Where we use providers based in the UK, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-UK Privacy Shield.
Photon Orgone is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
Photon Orgone may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.
What we collect
We may collect the following information:
- Name and payment details
- Contact information including email address
- Demographic information such as postcode, preferences and interests
- Other information relevant to customer surveys and/or offers
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
- To process your order and obtain payment
- Internal record keeping
- We may use the information to improve our products and services
- We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided
- From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
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 use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Data aggregation, analytics and profile creation
We may analyse your browsing behaviour to draw inferences and create profiles about your personal preferences and behaviours. We may then use such information for the purposes described below;
Behavioural advertising and cross platform targeting
(a) Served by us
We may use your information (including profile data) to serve you with advertising, which is relevant to you, on our websites and the websites of third parties.
(b) Served by third parties on our websites
(c) Served by third parties on third party websites
We may provide your personal information (including profile data) to third parties who may then use it in combination with personal information that they have collected from you to serve you with relevant advertising on third party websites.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
- Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
- If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the Data Protection Act 1998. If you would like a copy of the information held on you please write to us.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible. We will promptly correct any information found to be incorrect.