Privacy Policy

Last updated October 02, 2024

This Privacy Notice for Originate Limited ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services.

Summary of Key Points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

Table of Contents

  1. What Information Do We Collect?
  2. How Do We Process Your Information?
  3. What Legal Bases Do We Rely On to Process Your Personal Information?
  4. When and With Whom Do We Share Your Personal Information?
  5. Do We Use Cookies and Other Tracking Technologies?
  6. How Long Do We Keep Your Information?
  7. How Do We Keep Your Information Safe?
  8. Do We Collect Information from Minors?
  9. What Are Your Privacy Rights?
  10. Controls for Do-Not-Track Features
  11. Do United States Residents Have Specific Privacy Rights?
  12. Do We Make Updates to This Notice?
  13. How Can You Review, Update, or Delete the Data We Collect From You?

1. What Information Do We Collect?

Personal Information You Disclose to Us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

Sensitive Information: We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information Automatically Collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission to use your personal information for a specific purpose, or in situations where your permission can be inferred.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

4. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

5. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. Opt out of Google Analytics.

6. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law.

7. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process.

8. Do We Collect Information from Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age.

9. What Are Your Privacy Rights?

In Short: Depending on where you are located geographically, you have rights that allow you greater access to and control over your personal information.

In some regions, you have certain rights under applicable data protection laws. These may include:

To exercise these rights, you can contact us by visiting drop20.info/consent

10. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature.

At this stage, we do not respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

11. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of certain states, you may have specific privacy rights.

Categories of Personal Information We Collect

Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name NO
B. Personal information as defined in the California Customer Records statute Name, contact information, education, employment, employment history, and financial information NO
L. Sensitive personal Information NO

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail.

12. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice.

13. How Can You Review, Update, or Delete the Data We Collect From You?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information.

To request to review, update, or delete your personal information, please visit: drop20.info/consent.