Website and Privacy Policy

General Disclaimer of Liability for Content

1    The Omega Research Foundation (‘Omega’) is providing this site on an ‘as is’ basis and makes no representations or warranties of any kind with respect to this site or its contents and disclaims all such representations and warranties.  In addition, Omega makes no representations or warranties about the accuracy, completeness, or suitability for any purpose of the information and related graphics published in this site. The information contained in this site may contain technical inaccuracies or typographical errors. All liability of Omega howsoever arising for any such inaccuracies or errors is expressly excluded to the fullest extent permitted by law.

2    Neither Omega nor any of its directors, employees or other representatives will be liable for loss or damage arising out of or in connection with the use of this site or the material featured on the site.  This is a comprehensive limitation of liability that applies to all damages of any kind, including (without limitation) compensatory, direct, indirect or consequential damages, loss of data, income or profit, loss of or damage to property and claims of third parties.

3    Notwithstanding the foregoing, none of the exclusions and limitations in the clause are intended to limit any rights you may have as a consumer under local law or other statutory rights which may not be excluded nor in any way to exclude or limit Omega liability to you for death or personal injury resulting from our negligence or that of our employees or agents.

4        All information contained on this site (unless expressly stated) is both the property of the Omega Research Foundation or duly stated partner organisation. The material contained on the website may not be subject to any citation, reproduction or copy without the express permission of the Omega Research Foundation. All limitations to liability as outlined in Section 2 stand in regard to information hosted on the site.    

PRIVACY POLICY

Omega Research Foundation Limited (“Omega”, “we”, “us” or “our”) is a company limited by guarantee registered in England and Wales (with registered company number 05224240) and a registered office address at Bridge 5 Mill, 22a Beswick Street, Ancoats, Manchester, M4 7HR, United Kingdom. Omega Research Foundation Limited is also registered with the Charity Commission for England and Wales (with charity number 1105918).

Omega is committed to protecting and respecting your privacy. When you visit Omega’s website at www.omegaresearchfoundation.org, become a member of the Omega community, or if we are undertaking research about you or an organisation or government that you work for or are associated with, we will collect, store and process certain data about you. This privacy policy (“Privacy Policy”) sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us. Please read the following carefully to understand how we will use your personal data. 

For the purpose of data protection legislation in the UK, we are the controller of your personal data.

1. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS?

• Contact details data: This may include name, email address, phone number and organisation name. This information will be collected by us if you communicate with us, for example if you use the ‘contact’ links on our website or communicate with us via email or if you provide us with your business card or email address at training courses and other events. 

• Session data: This includes your IP address, your device’s unique identifier details, browser details including version, device operating system, time zone setting and time/date of access requests, the amount of data transmitted and the requesting provider. We may also capture other information about visits to our website such as pages viewed and traffic patterns. 

• Cookie data: Cookies are small files which are downloaded to your device when accessing our platform. Most web browsers automatically accept cookies. Please refer to paragraph 3 below for full details about our use of cookies.

• Research data: The research we undertake may involve collecting and processing various categories of data including images and videos, personal details, family details, lifestyle and social circumstances, membership details, goods and services, financial details, education, employment details, visual images, personal appearance and behaviour. In carrying out research, we may also collect and process information relating to criminal offences and alleged offences, criminal proceedings, outcomes and sentences. 

2. PURPOSES FOR COLLECTING PERSONAL DATA

We may collect data and process personal data for the following purposes:

• to enable us to provide a voluntary service for the benefit of the public interest as specified in our constitution, including to advance the education of the public in the subject of international peace, human rights and the causes of conflict;

• to monitor the international trade in military, security and police equipment (“MSP”) in the pursuit of responsibility, transparency and accountability;

• to provide human rights organisations, the media, key decision-makers and the public with timely and accurate case study information on the MSP trade;

• to work with non-governmental organisations (“NGOs”) and media agencies to highlight breaches in regulations governing transfers of MSP equipment;

• to provide torture survivor support groups with information that enables them to seek legal redress from the governments and/or companies that produce and trade MSP equipment;

• to provide to those involved in the prevention of crime;

• for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• to administer membership records and to maintain our own accounts and records; 

• to fundraise and promote the interests of the charity. We may also use your personal data to send direct marketing to you in order to fundraise and promote the interests of our charity where we are legally permitted to do so or where you have consented to receiving direct marketing from us. Where we process your information for direct marketing, we are relying on your consent as a means to process your information where legally required to do so. Individuals may be contacted by post, email, telephone or such other means as we regard as appropriate and as legally permitted; 

• to acknowledge and respond to communications;

• as part of our efforts to keep our website and members safe and secure;

• to administer, maintain and improve our website; and

• to meet legal or regulatory requirements. We are required to comply with certain legal and regulatory requirements when providing our products and services and we may process personal data in order to comply with those requirements, which may include monitoring and recording communications.  Occasionally, we may be asked to provide certain information to regulators or law enforcement agencies and we will comply with these requests where legally required or permitted.

The legal basis for our use of your personal data is one of the following,:

• the processing is necessary for the performance of an agreement to which you are a party;

• the processing is necessary for compliance with a legal obligation to which we are subject; or

• the processing is necessary for a legitimate business interest that is not overridden by your interests, rights and freedoms which require protection.

Where none of the above applies, your consent (which we will ask for before we process your personal data) or if we have not obtained your consent we may be relying on the exemption for journalism (see below for more detail).

3. COOKIES

Our website uses the following categories of cookies:

• Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to load webpages.

• Analytical/performance cookies: These cookies allow us to recognise and count the number of visitors to our website and to see how visitors move around our website. This helps us to improve the way our website works, for example, by ensuring that visitors are finding what they are looking for easily.

• Donate Cookie: This is provided by the Charities Aid Foundation. When you use the Widget and the Donate Button on our website you are agreeing to the use of this cookie to enable the Charities Aid Foundation to process your donation on our behalf.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. 

You may block cookies by updating the relevant settings on your device or browser to allow you to refuse the setting of some or all types of cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our site.

4. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We may need to share your personal data with selected third parties in the following limited circumstances:

• Our members: We may share data with Omega’s other members, for example research data you submit to us may be accessible by other Omega members who contribute to our research activities. 

• NGOs and appropriate governmental organisations: Certain data you submit to us, for example research data, may be shared with NGOs and/or governmental organisations (but only where such sharing is appropriate) for example where an NGO wants to publish Omega’s research reports or a governmental organisation (such as the European Commission) wants to fund Omega’s activities and/or gain access to research published by Omega.

• Third party service providers: This may include providers of certain systems and services that we use to host, administer and maintain our website, including for example the servers used to host our website. For example, our website and databases are developed and maintained by third party contractors and donations are currently collected on our behalf by the Charities Aid Foundation.

• Third party service providers for marketing purposes: If you explicitly opt in to any marketing from Omega, certain data may be shared with third party service providers we use to help us carry out marketing including, for example, third party marketing automation platforms.

• To comply with legal or regulatory requests: If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, we may share your personal data with a regulator or law enforcement agency.

5. PRACTICES REGARDING EXTRA-EEA TRANSFERS OF PERSONAL DATA

We may transfer your personal data to other non-governmental organisations based overseas that we work with. Accordingly, your personal data may be transferred outside of the European Union (“EU”).

When using data as described in this notice, data about you may be transferred either within or outside the country or territory where it was collected, including to a country, territory or international organisation that may not have UK and/or EU equivalent data protection standards.

In all cases, the transfer will be on the basis of a European Commission adequacy decision or we will implement adequate measures, for example the EU Model Contracts, and including appropriate security measures, for the protection of personal data in those countries, territories or international organisations in accordance with applicable data protection laws.

6. THIRD PARTY WEBSITES

Our website may contain links to third party websites. If you follow a link to a third party website, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites.

7. DATA RETENTION

By using our website, you consent for us to store your personal data in line with legal, regulatory, financial and good-practice requirements.

We apply a general rule of keeping your personal data for as long as required to fulfil the purposes for which it was collected. However, in some circumstances we may retain personal data for longer periods of time, for example if your personal data forms part of our research data we may keep your personal data indefinitely and in these circumstances we rely on the exemption for journalism (see below for more detail).

We may also retain your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

We maintain a retention procedure which we apply to records in our care. In all cases, where your information is no longer required we will ensure it is disposed of in a secure manner.

8. EXEMPTION FOR JOURNALISM

Due to the nature of our organisation, there may be times where we rely on the exemption for journalism as provided for by applicable law in relation to how we process the personal data of certain individuals.

Whenever we rely on the exemption for journalism:

(a) the processing of the personal data in question is being carried out with a view to the publication by us of journalistic material; 

(b) we reasonably believe that the publication of that journalistic material is in the public interest; and

(c) we reasonably believe that our compliance with applicable law (but for the exemption) is not compatible with such journalism.

In determining whether publication by us of journalistic material is in the public interest, we take into account the special importance of the public interest in the freedom of expression and information and we have regard to those codes of practice and guidelines which, in our reasonable opinion, are relevant to the publication of the journalistic material.

9. SECURITY

We take data security seriously. We implement appropriate and resilient security systems and protocols to protect the personal data we store.

However, Omega reminds you that transmission of data via the internet is never 100% secure. We cannot guarantee the security of information transmitted to or from our servers, and any such transmission is at your own risk. In particular, please keep in mind that if you voluntarily disclose your personal information online in a non-protected environment (such as a message board or in chat areas), that information could theoretically be collected and used by other members and would be outside of Omega’s control.

Due to the sensitivity of certain data that Omega collects in the course of conducting our public benefit research activities, all members should take precaution to protect the security of their devices and data online. More information can be found at the following website: https://www.cyberaware.gov.uk/

10. ACCESSING YOUR PERSONAL DATA AND YOUR RIGHTS

As a result of us collecting and processing your personal data, you may have some or all of the rights in respect of your personal data:

• to access personal data we hold on you;

• to request us to make any changes to your personal data if it is inaccurate or incomplete;

• to request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances;

• to receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the data is carried out by automated means and is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party to; or (iii) steps taken at your request prior to entering into a contract with us ;

• to object to, or restrict, our processing of your personal data in certain circumstances;

• if we use your personal data for direct marketing, you can ask us to stop and we will comply with your request; 

• if we use your personal data on the basis of having a legitimate interest, you can object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection;

• to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you; and

• to lodge a complaint with a data protection supervisory body, which at present in the United Kingdom, is the Information Commissioner’s Office.

In some circumstances where we rely on the exemption for journalism (see above for more detail), some or all of the rights listed above that you may have been able to exercise under applicable law may not be available to you.

11. CONTACTING US AND CHANGES TO YOUR PERSONAL DATA

If you have any questions or comments about this Privacy Policy or your personal data, or if you want to exercise any of your rights, including as set out in paragraph 10 above, or you wish to withdraw your consent where we have stated we are processing your personal data based on your consent, then please contact Omega Research Foundation Limited at:info@omegaresearchfoundation.org or write to us at: Bridge 5 Mill, 22a Beswick Street, Ancoats, Manchester, M4 7HR, United Kingdom. 

12. CHANGES TO THIS PRIVACY POLICY

Any changes we may make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to keep informed of updates or changes to this Privacy Policy.

This Privacy Policy was last updated in June 2018.