1. Who we are
This privacy policy explains how SMYL Limited ("SMYL", "we", "us", "our"), a company registered in England and Wales under company number 05553671, whose registered office is at 48-52 Penny Lane, Mossley Hill, Liverpool, United Kingdom, L18 1DG, collects, uses, and protects personal data when you visit ogre365.co.uk ("the Site"), enquire about our OGRE platform, or become a customer.
We are the data controller for the personal data described in this policy, unless stated otherwise. Our nominated contact for data protection matters is Girish Bhatkal / hello@ogre365.co.uk.
If you have any questions about this policy or how we handle your personal data, please contact us at hello@ogre365.co.uk.
2. What personal data we collect
Depending on how you interact with us, we may collect:
Information you give us directly, such as when you fill in a contact or enquiry form, book a demo, or correspond with us by email or phone:
- Name
- Job title and organisation name
- Email address
- Phone number
- Details of your enquiry or the message content you submit
Information we collect automatically when you visit the Site:
- Log data (IP address, browser type and version, device information, referring pages, pages visited, and timestamps)
- Cookie data (see Section 6, Cookies, below)
Information relating to the OGRE platform, if you or your organisation become a customer, which is governed separately by our customer agreement and any applicable Data Processing Agreement. This may include data about your fleet, vehicles, drivers, contracts, and operational records that you or your organisation input into the platform. Where SMYL processes such data on your organisation's behalf as a data processor, the terms of our customer agreement and Data Processing Agreement take precedence over this general website privacy policy for that data.
3. How we use your personal data
We use your personal data for the following purposes, and on the following legal bases under UK GDPR:
| Purpose | Legal basis |
|---|---|
| Responding to your enquiries and providing information you have requested | Legitimate interests (to respond to enquiries) / Steps taken at your request prior to entering into a contract |
| Booking and administering demos or calls | Steps taken at your request prior to entering into a contract |
| Providing and administering the OGRE platform to customers | Performance of a contract |
| Sending you marketing communications about OGRE (where you have opted in, or where permitted under the "soft opt-in" rules for existing customers) | Consent, or legitimate interests |
| Improving the Site and understanding how visitors use it | Legitimate interests |
| Complying with our legal and regulatory obligations | Legal obligation |
You have the right to withdraw consent at any time where we rely on consent to process your personal data, and to object to processing based on legitimate interests, as set out in Section 8 below.
4. Who we share your data with
We may share your personal data with:
- Service providers who support our business operations, such as hosting providers, email and CRM platforms, and IT support providers, who process data on our behalf under contract.
- Microsoft, as OGRE is built on Microsoft infrastructure (including Microsoft Dynamics 365, Azure, and related services); relevant operational data may be processed within Microsoft's cloud environment as part of delivering the platform.
- Professional advisers, such as our lawyers, accountants, and insurers, where necessary.
- Regulatory or law enforcement bodies, where we are required to do so by law.
- A buyer or prospective buyer, if we sell or transfer all or part of our business or assets.
We do not sell your personal data to third parties.
5. International transfers
Where any of the third parties referenced above are located outside the UK, we ensure an adequate level of protection is in place for your personal data, such as reliance on an adequacy decision, the UK International Data Transfer Agreement, or the EU Standard Contractual Clauses (as applicable), before any such transfer takes place.
6. Cookies
We use cookies and similar technologies on the Site to:
- Enable core site functionality;
- Understand how visitors use the Site, so we can improve it (analytics cookies);
- Where applicable, support marketing and remarketing activity.
You can control or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Site.
[If a cookie consent banner/tool is in use, list the specific categories of cookies and their names/providers here, e.g. Google Analytics, etc. This section should be finalised once the actual cookies in use on the live Site are audited.]
7. How long we keep your data
We retain personal data only for as long as necessary for the purposes set out in this policy, including to satisfy any legal, accounting, or reporting requirements. As a general guide:
- Enquiry and contact form data: retained for up to [X] months if no further engagement occurs, after which it is deleted or anonymised.
- Customer account and platform data: retained for the duration of the customer relationship and for a period afterwards as required by contract and law, as set out in our customer agreement.
8. Your rights
Under UK data protection law, you have the right to:
- Access the personal data we hold about you;
- Rectify inaccurate or incomplete personal data;
- Erase your personal data in certain circumstances;
- Restrict our processing of your personal data in certain circumstances;
- Object to our processing of your personal data, including for direct marketing;
- Data portability, allowing you to obtain and reuse your personal data for your own purposes;
- Withdraw consent at any time, where we rely on consent as the legal basis for processing.
To exercise any of these rights, please contact us at hello@ogre365.co.uk. We may need to verify your identity before responding.
You also have the right to lodge a complaint with the UK's supervisory authority, the Information Commissioner's Office (ICO), at ico.org.uk, if you believe we have not handled your personal data in accordance with the law.
9. Security
We take appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction, or damage, consistent with the standards expected of a platform built on Microsoft's enterprise-grade cloud infrastructure.
10. Children
This Site is intended for business use and is not directed at, nor do we knowingly collect personal data from, individuals under the age of 18.
11. Changes to this policy
We may update this privacy policy from time to time. Any changes will be posted on this page with an updated "last updated" date. We encourage you to review this policy periodically.
12. Contact us
If you have any questions about this privacy policy or how we handle your personal data, please contact us at:
Email: hello@ogre365.co.uk
Post: 48-52 Penny Lane, Mossley Hill, Liverpool, United Kingdom, L18 1DG