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Privacy Policy

PRIVACY POLICY – OVERWATCH RESEARCH LIMITED

Thank you for trusting Overwatch Research Limited (we, us or Overwatch) to be responsible for your personal data, which we want you to know that we take seriously.

This privacy policy (policy) informs you about how we look after your personal data when you interact with us as one of our customers or suppliers (or as an employee, representative of, or authorised user of, same), visit us at our premises, visit or use our website www.overwatchresearch.com (regardless of where you visit it from) (our website) including software applications such as our experimental tracking software platform for pre-clinical in vivo research. accessed via https://app.overwatchresearch.com/login (the Services). Any data that we collect through the Services shall be known as the Customer Data.

It also informs you how we will look after your personal data when, and about your privacy rights and how the law protects you. It does not cover any third party website you have used to access our website or the Services or any third party website that you access from them. It applies to all processing of personal data undertaken by Overwatch other than processing of personal information relating to our employees or consultants, which is dealt with under separate internal policies.

It is important that you read this policy so that you are fully aware of how and why we are using your data.

Before using the Services, you individually, will need to have been granted a licence to access the Services by the organisation on whose behalf you are using the Services who shall have a valid contract with us to access same (the Customer). If you are accessing the Services you will also be required to personally agree to this policy.

1. WHO WE ARE

1.1 Contact Details

Our full details are:

Full Name of Legal Entity: Overwatch Research Limited, a company incorporated in Northern Ireland under registered company number NI645015. Email Address: [email protected] Postal Address: 18 Ormeau Avenue, Ormeau Baths, Belfast, Northern Ireland, BT2 8HS. ICO Registration Number: ZA804289 (this is the number under which we are registered with the UK Information Commissioner’s Office as a fee paying data controller).

1.2 Under the UK General Data Protection Regulation or the EU General Data Protection Regulation (collectively GDPR) and other relevant data protection legislation, we act as both a data controller (i.e. where we make decisions) in relation to your personal data that we collect, as well as a data processor (i.e. process data broadly in accordance with your instructions.

When we act as a Data Processor: When as a user you use the Services to process personal data, or we process personal data on your behalf, whether through our provision of the Services to you or otherwise, we act as a data processor. Under these circumstances, you or the Customer may act as a data controller or data processor yourself, and we will act as either a processor or a sub-processor. Whenever we act as a processor, or a sub-processor, we will be restricted in the manner and purpose for which we can use personal data (including where applicable in the manner outlined in this policy) and we will also be subject to other obligations under data protection legislation.

When we act as a Data Controller: By contrast, when we collect personal data and determine the purposes and means of processing that personal data – for example, for administration or access processes, or contact information as explained below – we act as a data controller.

1.3 Third-Party Links

Our website and the Services may include links to third-party website, widgets, 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 or applications and are not responsible for them or their privacy statements.

2. WHAT KIND OF PERSONAL DATA DOES OVERWATCH PROCESS?

INFORMATION YOU SUPPLY TO US

2.1 General Personal Data - This is personal information about you that you share with us by online forms on our website, through email, through the post, on the telephone, when you register to use the Services, when you complete customer surveys, engage with our customer services team, engage Overwatch to provide Services or by any other means.

Typically, when you generally interact with Overwatch on behalf of a Customer or a supplier you may provide information about yourself, as well as other data about your business, including your full name, job title, billing address, business name, business email address, telephone and/or mobile phone number and other contact details. You may provide similar information where you contact us.

Customer Data:

When you sign up to use the Services you will be required to provide your name and email address, alongside other non-personal details. When using the Services, you may also (but are not required to) upload other personal data relating to yourself or others and will provide personal data when you report any technical or service issues in relation to our website or Services, including relevant notes about any issues and how we responded to resolve these, as well as details of any payments you have made through the Services.

2.2 Feedback Data: If you agree to take part in feedback sessions to improve the Services, or provide a suggestion, this may be recorded or shared among the development team to feed into our roadmap if applicable. Any general feedback you provide shall be non-confidential and non-proprietary, and you agree we may use it to improve our Services without credit to you.

2.3 Financial Details: Where you are a supplier and provide us with your financial details in order to facilitate payments by us to you or a customer contacting us to provide your financial details in the context of any returns or overpayment, we will collect these financial details. All such details will be kept securely.

2.4 Verbal Information: If you provide verbal personal information that you give us consent to use you will have such consent confirmed back to you in writing.

2.5 Marketing Information: We do not currently, but may in future, collect such information. If so, you will be able to communicate your preferences in receiving marketing from us and our third parties and your communication preferences (including details you provide when you opt-in to receive marketing communications from us).

2.6 Third Party Data: Where you are sharing personal data that does not directly relate to you (e.g. your representatives that legally act on your behalf), you must ensure you have the consent to do so and have shared this policy with that person/those people, including where you are acting to register other individuals on their behalf.

IF YOU FAIL TO PROVIDE PERSONAL DATA

2.7 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 products). In this case, we may not be able to fulfil any order you place with us, but we will notify you if this is the case at the time.

PERSONAL DATA WE COLLECT

2.8 Technical Data from the Services or our website: We use certain technical services to gather certain technical and usage data whenever you use the Services or our website, as detailed below:

The Services

Usage data will be collected only via AWS, Google Analytics and Intercom, a third party service provider. This data is aggregated and anonymous and does not capture information regarding any of your interactions which are specifically outside your intentioned engagement. We also have access to any usage data processed by the Services.

You will be personally identifiable from any such data, as it will be tied to your user account for the Services.

Please see our cookies policy which can be found at: www.overwatchresearch.com/legal/cookies-policy.

Website

We use certain technical services to gather technical data online whenever you use our website including information about your device and your visits to our website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed.

We collect this data using cookies and other similar technologies. There is (currently) no login functionality on our website, so you will not be personally identifiable from such data.

Please see our cookie policy in relation to our website which can be found at: www.overwatchresearch.com/legal/cookies-policy

PERSONAL DATA WE RECEIVE FROM THIRD-PARTIES

2.9 Device Data: analytics providers such as Google Analytics and Intercom (in respect of the Services) or Google Analytics (in respect of our website) based inside the UK or EU.

2.10 Social Media: publicly available information through social media sites, such as Facebook, LinkedIn, Twitter and Google. This includes where you have interacted with us through social media platforms, in which case we may receive profile information about you which can include your name, address, telephone number(s) and/or your business contact details. This information would be used to respond to your interest, to fulfil a request from you and/or to send you future information and offers, where you have given clear consent to do so.

2.11 Publicly Available Information: We may collect personal information about our Customers from other publicly available sources. This may include your name, address and other publicly available information. As far as passible, we ensure that where any third-parties are involved in suppling such information, that they are compliant to do so.

2.12 Services: Users of the Services may collect, store and process personal data about you when using the platform. As detailed in the note below we have requested that no sensitive or special category data is collected through the Services, but we have no obligation to enforce this provision, and we do not control users’ use or processing of personal data through the Services.

IMPORTANT – PLEASE NOTE: Our agreement with the Customer for the Services may require users to refrain from uploading or processing any data using the Services in violation of applicable laws, including not to process any personal data without valid legal grounds, not to process any sensitive or special categories of data (such as financial information, medical data, information about religious or political affiliations etc) and not to infringe any third party’s other rights using the Services. We require all users to agree to adhere to these terms at all times, but do not actively monitor content uploaded or processed using the Services and are not responsible for enforcing the relevant terms. If you are reviewing this policy because you believe your or your organisation’s data has been used in violation of the relevant terms for either product, please contact us.

2.13 Other: from time to time, we may receive personal information from other sources. We will always endeavour to ensure such information is provided from reputable sources, who are legally compliant to provide such information.

KEEPING YOUR PERSONAL DATA UP TO DATE

2.14 It is important that the data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

3. WHAT INFORMATION IS NOT COLLECTED?

3.1 We do not intentionally collect sensitive personal data or special category data (including details about your race or ethnicity, religious or philosophical beliefs, medical information, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data, social security numbers). Nor do we collect any information about criminal convictions and offences. As noted above, our agreement with the Customer for use of the Services will typically include restrictions on any of users using the Services to collect such data (or financial information) but as noted we do not proactively monitor this, and cannot be held responsible where users breach these restrictions.

3.2 If you're a child under the age of 16 (or are otherwise younger than the legal age limit required in the country in which you reside), you may not have a user account for the Services or provide personal information to us via our website. Overwatch does not knowingly collect information from or direct any of our content specifically to children under relevant ages.

If we learn or have reason to suspect that you are a user who meets these criteria, we will unfortunately have to close your account for the Services.

If you are a child aged between 16 and 18 using our Services or website from the UK or European Union, you must have informed your parents or guardians of this, of the terms of this policy, and have their consent to do so.

4. HOW IS INFORMATION USED?

4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data (other than Customer Data) in the following circumstances:

4.1.1 Where we need to perform the contract we are about to enter into or have entered into with you, to keep internal records for administration purposes related to such contracts, for the purposes contemplated in any separate terms of use for our website that you have entered into, including for the purposes set out in the “Our Standard Business Operations” section below. This is the ground we rely upon to process Customer Data our customers upload when using our Services.

4.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

4.1.3 Where we need to comply with a legal or regulatory obligation

4.2 We only use Customer Data in the following circumstances:

4.2.1 To operate, maintain and improve the Services and its related features.

4.2.2 Where necessary to give you to access the Services and related features, engage with the content or otherwise interact with the Services.

4.2.3 To provide technical support or customer service.

4.2.4 To communicate with you about the Services and any relevant updates.

4.2.5 For the purposes of detection and prevention of fraud or other security or legal incidents.

4.2.6 Where we need to comply with a legal or regulatory obligation.

4.2.7 For the purposes of providing, enhancing or improving the Services.

4.3 Generally, we do not rely on consent as a legal basis for processing your personal data other as set out below in relation to marketing and testimonials. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

4.4 Our Standard Business Operations:

4.4.1 to provide the services and any other responsibilities that we contract to do so with you

4.4.2 To provide you with information that you request from us;

4.4.3 To confirm your identity as a natural living person; and

4.4.4 As part of our billing, payments and recovery processes.

We may also use contact information to notify you of any issues which might impact the provision of our Services to you or your use of the Services.

4.5 Marketing

Although we do not currently provide any marketing services, we maintain multiple contact lists (with email addresses and other information) which may allow us in future to communicate with individuals who do business with us or who have expressed an interest in our Services.

We may contact you to respond to requests that you make, notify you of changes to the Services, for marketing purposes, or to otherwise inform you of information related to our business.

You will only receive marketing communications from us if you have opted to receive them. This includes where you have consented to being contacted by us by email or telephone. You can opt in over the phone, by email, or online. 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 or by contacting us, as appropriate, at any time.

Where you opt out of receiving marketing messages, this will not apply to personal data (other than Customer Data) provided to us as a result of your engagement with us to provide Services to you.

We will never sell your personal data to any third party (as noted below).

4.6 Testimonials

We may post customer testimonials and comments on our website or other platforms, which may contain personal data. We obtain each customer's consent via email prior to posting the customer's name and testimonial.

4.7 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 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.

4.8 Legal Requirements

We will keep and use your data in terms of any legal or regulatory requirements that we have and can use your data to protect our legal position, if legal action is required, including the recovery of any outstanding debts.

By way of further example, we will share your personal data with the relevant agencies and without notice, where we are requested to or suspect fraudulent activities, money laundering, terrorist related activities.

4.9 Customer Data

Whilst we do have access to personal data stored on the Services, i.e. what we call Customer Data in these terms, we do not process such data otherwise than in accordance with your instructions. It belongs to you, and you are responsible for it, as well as for making sure that such Customer Data complies with the relevant terms we have agreed with the person who has authorised your use of the Services.

We do not access any information (including personal data contained in same) you have stored using your user account for the relevant Services unless under the circumstances described above. We will only use any feedback data you have provided internally (although it will be stored on the servers of the third party hosting services providers we use to store such data) unless agreed otherwise.

4.10 Website Administration and Customisation

We may use the information we collect about you (with the exception of Customer Data) for a variety of website administration purposes, and customisation purposes. For example, we use your information to process your registration request, provide you with services and communications that you have requested, send you email updates and other communications, customise features and advertising that appear on our website, deliver our website content to you, measure Website traffic, measure user interests and traffic patterns, and improve our website and the services and features offered via our website.

4.11 Aggregated or Non-Identifying Information

Non-identifying information includes information collected from or about you that does not personally identify you – including aggregated information. Overwatch treats IP addresses, log file information, anonymised feedback, user agent strings, computer IDs, and related information as non-identifying information, except if applicable law suggest us to do otherwise. Overwatch may use non-identifying information for any purpose.

Certain jurisdictions, including the United Kingdom and European Union, may deem IP addresses and/or Unique IDs, to be personal data. Accordingly, for persons in such jurisdictions, our use of Non-Identifying Information as described in this policy should be assumed to include IP address and Unique ID data.

5. WHAT INFORMATION IS SHARED?

5.1 We do not disclose personal data outside Overwatch, except in the situations listed in this section or in the section below on Compelled Disclosure, but may have to share your personal data with the categories of data processors or data controllers set out below for the purposes set out in in above or otherwise below:

5.1.1 with HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances (excluding private Customer Data – unless we are subject to a Compelled Disclosure);

5.1.2 with third party purchasers, if we buy, sell or merge any business or assets of our business and are required to share data as part of the buying, selling or merger agreement or if our assets are acquired by a third-party, and data is transferred as part of the purchased assets. If any such change happens, we will ensure that it is under terms that preserve the confidentiality of your personal data, and we will notify you on our website or by email before any transfer of your personal data. Any purchaser would be bound by the terms of this policy and our relevant Terms of Use for the Services;

5.1.3 in respect of your Customer Data. with our Customer, on whose behalf you have been authorised to access the Services, and anyone else to whom they may grant administrative privileges through the Services from time to time, who shall act as a data controller with respect to your personal data;

5.1.4 with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, where they have a need to know same for any of the purposes set out above (excluding private Customer Data);

5.1.5 with reputable and trusted third-parties where we have asked them to contact you on our behalf, where you have given us consent, it is part of our contractual agreement, is a legal requirement or there is clear legitimate interest between us (these services may include sending you email, calling you by telephone, sending you information through the post etc.) (excluding Customer Data);

5.1.6 with specific selected third parties, determined by us, if you breach any agreement with us, including so as to enforce our rights against you, including credit-reference agencies, debt-collection firms or service providers, solicitors or barristers and law enforcement agencies (if applicable) (excluding private Customer Data); and

5.1.7 with service providers acting as processors based in the European Union or United Kingdom who provide IT and system administration services, including for the performance of our contract with you, as set out below: When we transfer your data to our service providers, we remain responsible for it:

with processors offering software tools, or USA, EU or UK based external servers (including externally provided original and backup servers), that are used to store personal data provided by you on our behalf (our current servers are maintained by Amazon Web Services, whose privacy policies are available at https://aws.amazon.com/privacy/. By default, and unless we have agreed otherwise in writing with the location of these servers will be within the EU, where the organisation on whose behalf you are using the Services is based in the EU, or the USA, where the organisation on whose behalf you are using the Services is based in the USA has requested this; and

platforms providing support functionality to you as a user of our Services, for example Intercom, who will get access to your username, name, email address and any information you share through the Intercom API.

5.2 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 the minimal personal data required for the specified purposes, in accordance with our instructions, where they have agreed to privacy restrictions similar to our own policy.

5.3 We do not share, sell, rent, or trade personal data with third parties for their commercial purposes. We may also share personal data with your permission, so we can perform services you have requested.

6. HOW IS MY INFORMATION SECURED?

6.1 Overwatch takes all measures reasonably necessary to protect personal data from unauthorised access, alteration, or destruction, maintain data accuracy and help ensure the appropriate use of personal data. We follow generally accepted industry standards to protect the personal data we hold, both during transmission and once we receive it.

6.2 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 duties of confidentiality.

6.3 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.

6.4 No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

7. HOW IS INFORMATION COLLECTED AND STORED GLOBALLY?

7.1 Information that we collect will typically be stored and processed in the United Kingdom or the European Union in accordance with this policy. However, we understand that we have users from different countries and regions with different privacy expectations and local legal requirements, and we try to meet those needs and requirements.

7.2 We provide the same standard of privacy protection to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide. We work hard to comply with the applicable data privacy laws wherever we do business. Additionally, we require that if our vendors or affiliates have access to personal data, they must comply with applicable data privacy laws, including signing data transfer agreements such as EU standard contractual clause agreements, where required by law. In some cases, our Customer may have requested that the server on which the Customer Data is hosted is based in the USA, in which case we will comply with this requirement.

7.3 In particular:

7.3.1 we provide clear methods of unambiguous, informed consent at the time of data collection, when we do collect your personal data and if applicable. Where consent is not the applicable ground for processing, we will ensure that it has an appropriate ground for processing any personal data (including but not limited to contractual obligation or legitimate interest);

7.3.2 we collect only the minimum amount of personal data necessary, unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing;

7.3.3 we offer you simple methods of accessing, correcting, or deleting the data we have collected; and

7.3.4 we provide our users notice, choice, accountability, security, and access, and we limit the purpose for processing. We also provide our users a method of recourse and enforcement.

8. WHAT HAPPENS IF I HAVE A COMPLAINT?

8.1 If you have concerns about the way Overwatch is handling your personal data, please let us know immediately. We want to help and there are several ways available that you can contact us. You may also email us directly at [email protected] with the subject line "Data Privacy". We will respond within 21 days at the latest, unless required to respond earlier under relevant law.

8.2 If you are a data subject based in the UK or European Union, you may 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), or other competent supervisory authority of an EU member state if the Services are accessed outside the UK. We would appreciate the chance to deal with your concerns before you approach such bodies so would ask that you please contact us in the first instance.

9. HOW DO YOU RESPOND TO COMPELLED DISCLOSURE REQUIREMENTS?

9.1 Overwatch may disclose personal data or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar governmental order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large.

9.2 In complying with court orders and similar legal processes, Overwatch strives for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.

10. HOW CAN I ACCESS MY OWN PERSONAL INFORMATION?

If you're already a user, you may access, update, alter, or delete your basic user profile information by editing your user profile or contacting us.

Under certain circumstances, where you are a citizen of the European Union or UK, you have rights under data protection laws in relation to your personal data under GDPR.

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
  • Please 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 of your personal data where we are relying on a legitimate interest (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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the 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 data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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 may refuse to comply with your request in these circumstances.

Where you exercise one of your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to exercise such 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 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.

11. DATA RETENTION AND DELETION

Personal Data Generally

11.1 We will only retain your 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.

11.2 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 your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

11.3 We will keep your personal data for the term you have consented to, the contracted term between us where there is a legitimate interest for us to remain in contact with you, or for the legally required period, whichever is the longest.

11.4 By law we have to keep basic information about any of our customers (including contact, identity, financial and transaction data) for six years after you cease being a customer for tax purposes. For the purposes of contract administration, we will also store all data as long as the contract you have placed through us endures and for the six year limitation period thereafter in case you raise any claims in relation to any Services you have purchased from us. This section does not apply to Customer Data.

11.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

The Services and Customer Data

11.6 As all personal accounts relate to corporate organisations, and legally our Customers’ require a full audit of any interactions or information provided by you through the Services, it is not possible to cancel your account for the Services or initiate deletion of your personal data. Your account will typically be suspended by our Customer once you cease to work with them or be an authorised user under the applicable Customer terms, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, maintain security, and enforce our agreements, but barring legal requirements, the timeframe above will be observed for deletion.

11.7 We will endeavour to delete any Customer Data no later than 6 months after your account being terminated, or when you delete such Customer Data using your account. This is to synchronise deletion of such Customer Data with our data deletion cycles. Customer Data may be, irrevocably, deleted more quickly.

12. HOW DO YOU COMMUNICATE WITH USERS?

12.1 We will use your email address to communicate with you, if you've given us the OK, and only for the reasons you’ve permitted. Emails by default are not disclosed with other users. This will not change how we contact you, as we always utilise your primary email address.

12.2 Depending on your email settings, Overwatch may occasionally send notification emails about new features, requests for feedback, important policy changes, or to offer customer support. We may also send marketing emails, including ones featuring, services and products offered by our commercial partners, but only with your consent. There's an unsubscribe link located at the bottom of each of the emails we send you.

12.3 Our emails might contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we’re not sending you unwanted email. If you prefer not to receive pixel tags, please opt out of marketing emails.

13. WILL YOUR PRIVACY POLICY CHANGE?

If there are material changes to this policy or in how we use your personal data, we will prominently post such changes prior to implementing the change. We encourage you to periodically review this policy to be informed of how we are collecting and using your information.

We keep this policy under regular review, for example, to reflect changing business circumstances and legal developments.

Although most changes are likely to be minor, it may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next log on to use the Services. Otherwise, any changes shall be applicable without further notice.

This version one of this policy was last updated on 17 November 2021 and historic versions can be obtained by contacting us.

14. HOW CAN I CONTACT OVERWATCH?

Questions regarding our Privacy Policy or information practices should be directed to us via one of the contact methods that we provide.

15. LEGAL

This policy shall be governed by and interpreted in accordance with the laws of Northern Ireland and you irrevocably agree that the courts of Northern Ireland shall have exclusive jurisdiction to settle any dispute which may arise out of, under, or in connection with this policy.

Overwatch Research Ltd ("us", "we", or "our") operates the overwatchresearch.com website and app.overwatchresearch.com application (the "Service").

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

When you visit a third-party website or service that uses the Overwatch Service, any information collected through that website, including through the Overwatch Service, is governed by the owner of such third-party website.