Privacy Policy

Omni Bridgeway PRIVACY POLICY

Last updated: 9 December 2020

Omni Bridgeway (also "we", "our" or "us") is part of a group of companies. The Omni Bridgeway entity responsible for processing your personal data / information (“personal information”) is the member of the Omni Bridgeway Group that originally collects information from or about you. You can find out more about our Omni Bridgeway Group at https://omnibridgeway.com or by contacting us using the information in the Contact Us section below.

Updates

This Privacy Policy may change to reflect Omni Bridgeway's business, laws and technology. We will place any updates on our website https://omnibridgeway.com. Whenever you need to refer to this Privacy Policy you should refer to our website or contact us for the most up to date version. If we make material changes to this Privacy Policy, we will take additional steps to notify you, including by posting our website, through a pop-up notice, or via email. Where we are required to do so under applicable law, we will obtain your notified consent to such changes.     

Third Party Websites

You might find links to external third party websites on our website. This Privacy Policy does not apply to your use of a third party site and we are not responsible for the privacy practices of any such third party. You should check the privacy policies of any third party websites for information on how these third parties handle your personal information.

Do you have to provide your personal information?

The provision of your personal information to us is voluntary, however, to the extent that we require personal information to evaluate a legal claim, determine whether to enter into an agreement, carry out our duties under an agreement or comply with our legal obligations, the provision is mandatory in the sense that without the requested personal information, we reserve the right to:

  • not enter into an agreement with the (legal) person in respect of which the provision of personal information is required; or
  • suspend or terminate any existing agreement in respect of which the provision of personal information is required.

WHAT PERSONAL INFORMATION WE COLLECT, HOW AND WHY WE USE IT

How does Omni Bridgeway collect your personal information?

Omni Bridgeway generally collects personal information directly from you, your authorised representative or another third party.  For example, Omni Bridgeway may collect personal information about you when you deal with us over the telephone, when you send us correspondence (whether by letter, fax, e-mail or via the Omni Bridgeway website or the website of one of the wider group of companies and affiliates that are part of the Omni Bridgeway Group), when you request litigation funding via Omni Bridgeway’s website or when a representative of Omni Bridgeway meets with you.

Omni Bridgeway also collects personal information from third party sources to the extent permitted by applicable law, including:

  • our third party partners, including aggregators who provide personal information to us for share trading cases;
  • financial planners, pension funds, accountants, stock brokers, and insurers;
  • our clients, counterparties and suppliers (e.g. lawyers, advisors, credit rating agencies and other information service providers);
  • publicly maintained records or from the public domain generally (for example via the internet or social media platform).

If you provide us with personal information of other persons, please make sure that you obtain their consent to disclose their personal information to us for the purposes contained in this Privacy Policy and that such personal information is correct.

What personal information we collect

In the context of our activities, personal information that may be collected from you, or a third party (where applicable) includes:

  • your full name;
  • personal and business contact information (for example, phone number, email address, mailing address, home address);
  • job title and organisation/employer name;
  • financial and tax information (bank account numbers, share trading data and supporting documentation);
  • sound/voice recordings (voicemail / phone messages and sometimes telephone conversations) as permitted by applicable laws and with prior consent (where necessary);
  • information relating to claims;
  • national or government identifiers (e.g. social security numbers / national insurance / passport / driver’s license) as permitted by applicable laws;
  • demographic information;
  • information obtained from your use of our website (e.g. your IP address and how you navigate our website, see our Cookie Policy at Annexure A of this Policy for more information about this);
  • credit rating information as permitted by applicable laws;
  • information from fraud prevention agencies and/or due diligence information, as permitted by applicable laws, electoral roll, court records of debt judgements and bankruptcies and other publicly available sources, as noted further below; and/or
  • where you contact us, Omni Bridgeway may keep a record of the correspondence.

In order to provide clients with our services, Omni Bridgeway also collects information relating to the legal proceedings or claims for which funding is sought or being provided. Some of this information may contain your personal information (for example, procedural information as the parties to a dispute and their solvency status, cases involving family trusts and beneficiary details and relevant relationships (subject in each case to compliance with all relevant confidentiality restrictions), and other facts collected in respect of a claim.

Categories of personal information collected under the CCPAThe California Consumer Privacy Act (CCPA) requires that we explain the categories of personal information we collect as defined by the CCPA.  While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, generally, we may collect the following categories of personal information about California residents:

Categories Description
Identifiers Includes name, user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers; SSN, driver’s license number, passport number, tax ID and other government identifiers; and other similar identifiers.
Customer Records Includes name, account name, user ID, contact information, education and employment information, SSN and government identifiers, account number, and financial or payment information.  For example, this may include information collected when an individual registers for an account, purchases or orders our products and services, or enters into an agreement with us related to our products and services.
Commercial Information Includes records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
Usage Data Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our Site and other services, and our marketing emails and online ads.
Audio, Video and Electronic Data Includes audio, electronic, visual, thermal, olfactory, or similar information such as voicemail, phone messages and call recordings (e.g., of customer support calls).
Professional Information Includes professional and employment-related information (such as job title and employer name, business contact information and professional memberships).
Education Information Includes information about an individual’s educational history (such as the schools attended, degrees you were awarded, and associated dates).5 origin, political opinions and/or medical conditions in the context of a claim that we are funding, and in which you are a party or otherwise implicated.
Protected Classifications Includes characteristics of protected classifications under applicable federal and California laws, such as disability information and medical conditions, race or ethnic origin, or political opinions, in the context of a claim that we are funding, and in which you are a party or otherwise implicated.

We may collect the above categories of personal information about California residents from the following sources:

  • directly from the individual 
  • or investment partners and financial institutions
  • data analytics providers
  • social networks and third-party platforms
  • internet service providers, operating systems and platforms
  • government and law enforcement entities
  • other parties and legal representatives in litigation we are providing funding for data brokers

For what purposes we use your personal information

We collect, hold, disclose, use and otherwise process your personal information for the following business and commercial purposes:

  • to verify whether we wish to conclude an agreement with you or your organisation (*);
  • to provide our services and products (for example, for our legitimate interest in managing claim(s), reviewing and evaluating litigation funding prospects and other potential agreements, conducting legal proceedings, settling legal claims, and to perform contracts with our clients (including claim enforcement) and with our suppliers or vendors) (**);
  • to market our services and products to you, including informing you about legal and funding developments that may be of interest to you, and notifying you of Omni Bridgeway hosted events (unless you have notified us that you do not wish to receive marketing material, and where required by applicable law, with your prior consent) (**);
  • to administer and archive case-related information and our financial information (***);
  • to maintain commercial relationships with contact persons (****);
  • to communicate with you or other contact persons, including corresponding with you to resolve queries or complaints (*);
  • to analyse the use of our website, enhance its user friendliness and optimise it for website users (****);
  • if you are a prospective employee, to manage recruitment, work placement or internship processes, including considering applications, maintaining professional HR administration, and making offers and related activities (* / ***);
  • to purchase goods and services from you (*);
  • to help us manage or improve our services (**);
  • to be able to disclose necessary information to a potential or actual third party purchaser of our business, shares or assets (if your personal information is included as an asset of the business) (**);
  • to comply with our legal obligations including our tax, audit and company law requirements (***); and/or
  • to protect our assets, business and personnel (**).

Omni Bridgeway does not engage in automated individual decision making.

Legal basis for processing your personal information

If the data processing is governed by European data protection laws, or DIFC Law No. 5 of 2020 (“DIFC Law”) then all processing of your personal information is justified by a "legal basis" for processing. Such justified legal basis is that we may need to process your personal information:

  • (*) to perform a contract or take steps to enter into a contract with you and to provide you with our services for example, where you as an individual enter into a contract with us for litigation funding, or  that is required from you under the terms of use that apply to the use of our websites;
  • (**) for our legitimate interest, which derives from the purpose of our business activities, which include the evaluation and management of our client’s legal claims as part of our funding and recovery services;
  • (***) to comply with a relevant legal or regulatory obligation under EU, Member State or other jurisdictions' law that we are subject to for example carrying out right to work checks on recruitment applicants, and maintaining client information in accordance with tax, audit or company law requirements;
  • (****) for certain specific processing activities, such as sending email marketing (where this cannot be done on a legitimate interests basis) and retaining candidates’ personal information for longer than the period initially prescribed by applicable law, we ask your prior consent, this consent may be revoked at any time.

In certain other jurisdictions our processing of your personal information is based on prior notification to you (for example, through provision of this Privacy Policy to you) or on prior consent from you.

Special category personal information

In limited circumstances, we may process special categories of personal information, which are

categories of information that the relevant applicable law considers to be more sensitive. This may include information about your health, race or ethnic origin, or political opinions, in the context of a claim that we are funding, and in which you are a party or otherwise implicated. In the same context, we may also process information about criminal offences or convictions associated with you.

Whenever we process special category information subject to the GDPR, we will rely on a special exemption that permits us to process that information. Typically that will be because the processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity. Whenever we process criminal data, we will rely on an exemption under relevant Member State or UK law.

SHARING PERSONAL INFORMATION WITH OTHERS

Omni Bridgeway may share your personal information, as permitted by applicable law, for the following business and commercial purposes:

  • between members of the Omni Bridgeway group situated in a number of locations globally where such disclosure is necessary to provide you with our services and/or to manage our business. The list of Omni Bridgeway companies is at our Contact Us section below;
  • with third parties who help manage our business and/or deliver services or perform functions on our behalf. These include:
    • IT service providers who help manage our IT and back office systems (these service providers are located and store personal information in the EEA);
    • solicitors, barristers, bailiffs, advisors, auditors and translators – personal information from our case files are shared with suppliers who provide services on specific cases. These suppliers are usually established in the country where the legal proceedings take or are intended to take place (this can be anywhere in the world);
    • investment partners – limited personal information contained in case files may be shared with investors for investment decisions related to our cases;
  • with a defendant or respondent in proceedings in relation to which Omni Bridgeway has agreed to provide funding, for the purpose of Omni Bridgeway performing its obligations under an agreement or to comply with applicable law, such defendant or respondent could be located anywhere in the world;
  • with financial institutions in the context of legal proceedings, e.g. a bank to levy attachments on a bank account;
  • courts, arbitral tribunals, arbitral institutes – personal information from specific case files is shared with these bodies in the country where legal proceedings take or are intended to take place;
  • with local government organisations and agencies, courts, law enforcement and regulators to comply with applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
  • we may share in anonymised, statistical form, information regarding the visitors to our website, traffic patterns, and website usage with our affiliates and service providers such as “Google” (for example  use of “Google Analytics" services - see our Cookie Policy at Annexure A of this Policy for more information about this);
  • if, in the future, we sell or transfer some or all of our business, shares or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business, shares or assets and this may include personal information as an asset of the business;
  • with lawyers, law firms and related legal service providers in the context of a relevant claim. These parties agree or are legally bound to strict confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing legal confidential services; and/or
  • with our clients who may receive personal information contained in their case files.

Categories of personal information shared under the CCPA.  The CCPA requires that we explain how we may disclose personal information about California residents. While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in the table below we describe, generally, how we have disclosed” personal information about California residents in the prior 12 months.  For more information about these categories, see “Categories of personal information collected under the CCPA” above. 

Categories Categories of Third Parties to Whom We May Disclose this Information for a business purpose
Identifiers
  • service providers 
  • financial institutions
  • our advisors and agents
  • our affiliates and subsidiaries
  • courts, tribunal, and legal counsel or other parties in litigation we are funding
  • other government entities and law enforcement
  • data analytics providers
  • internet service providers, operating systems and platforms
Customer Records
  • service providers 
  • financial institutions
  • our advisors and agents
  • our affiliates and subsidiaries
  • courts, tribunal, and legal counsel or other parties in litigation we are funding
  • other government entities and law enforcement
  • internet service providers, operating systems and platforms
Commercial Information
  • service providers 
  • financial institutions
  • our advisors and agents
  • our affiliates and subsidiaries
  • courts, tribunal, and legal counsel or other parties in litigation we are funding
  • other government entities and law enforcement
  • internet service providers, operating systems and platforms
Usage Data
  • service providers 
  • our advisors and agents
  • our affiliates and subsidiaries
  • other government entities and law enforcement
  • data analytics providers
  • internet service providers, operating systems and platforms
Audio, Video and Electronic Data
  • service providers 
  • our advisors and agents
  • our affiliates and subsidiaries
  • other government entities and law enforcement
  • internet service providers, operating systems and platforms
Professional Information
  • service providers 
  • our advisors and agents
  • our affiliates and subsidiaries
  • courts, tribunal, and legal counsel or other parties in litigation we are funding
  • other government entities and law enforcement
Education Information
  • service providers 
  • our advisors and agents
  • our affiliates and subsidiaries
  • courts, tribunal, and legal counsel or other parties in litigation we are funding
  • other government entities and law enforcement
  • internet service providers, operating systems and platforms
Protected Classifications
  • service providers 
  • our advisors and agents
  • our affiliates and subsidiaries
  • courts, tribunal, and legal counsel or other parties in litigation we are funding
  • other government entities and law enforcement

DIRECT MARKETING

Omni Bridgeway may use personal information to let you know about our products and services that we believe will be of interest to you. As permitted by applicable laws, we may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you. 

Omni Bridgeway does not disclose any personal information it collects to third parties for the purpose of allowing them to directly market their products and/or services to you.

How you can manage your marketing preferences

To protect privacy rights and to ensure you have control over how we manage marketing with you:

  • [email protected]  or
  • [email protected] stating that you wish to unsubscribe from marketing communications from us. Alternatively, you can request to opt out by using any unsubscribe link in the marketing communication. Please do let us know whether you would like us to stop all forms of marketing or just a particular type (e.g. email).

TRANSFERRING PERSONAL INFORMATION GLOBALLY

We operate on a global basis. Accordingly, your personal information may be disclosed, transferred, stored or otherwise processed outside of your country of residence. The countries in which overseas recipients are located will depend on the circumstances of the services Omni Bridgeway provides you. These locations may be subject to a different standard of data protection than the laws in your country and will be accessible to law enforcement and/or regulatory authorities according to the applicable law of such jurisdictions.

  • Australia: If you reside in Australia, your personal information may be transferred outside of Australia to countries including the United Kingdom, the United States of America, United Arab Emirates, Singapore, Canada, the Netherlands, Germany and Switzerland. Where Omni Bridgeway discloses your personal information outside of Australia to a jurisdiction that does not have comparable privacy laws, Omni Bridgeway will take reasonable steps to ensure that your personal information is handled in accordance with the Australian Privacy Principles.
  • Singapore: If you reside in Singapore, your personal information may be transferred outside of Australia to countries including the United Kingdom, the United States of America, United Arab Emirates, Australia, Canada, the Netherlands, Germany and Switzerland. Where Omni Bridgeway discloses your personal information outside of Singapore to a jurisdiction that does not have comparable privacy laws, Omni Bridgeway will take reasonable steps to ensure that your personal information is handled in accordance with the requirements of the Personal Data Protection Act 2012.
  • Europe / the United Kingdom/United Arab Emirates (“UAE”): For Omni Bridgeway companies in the European Economic Area or the United Kingdom, or for Omni Bridgeway Advisory Ltd (“Omni Bridgeway DIFC”),  that process your personal information pursuant to European data protection laws (or, with respect to Omni Bridgeway DIFC, the DIFC Law): always only if required for the purposes set out in this Privacy Policy, your personal information may be transferred and stored in countries outside of the European Economic Area (or, with respect to Omni Bridgeway DIFC, the DIFC Law), including the United States of America, Australia, United Arab Emirates, Singapore, Canada and Switzerland, some of which are subject to different standards of data protection.

     

    In addition, in the context of litigation in countries outside the European Economic Area and the Dubai International Financial Centre, we will have to transfer relevant personal data relating to the case files to such other countries that may have different standards of data protection.  

    Where required, we will take appropriate steps to ensure that transfers of personal information are in accordance with applicable laws, such as:  

    • we will ensure transfers within Omni Group are covered by a data transfer agreement entered into by members of Omni Bridgeway Group using the EU Commission approved Standard Contractual Clauses which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within our group of companies;
    • where we transfer your personal information outside Omni Bridgeway Group or to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your personal information. Some of these assurances are the use of EU Standard Contractual Clauses approved by the EU Commission for the transfers of personal information to a third country adducing adequate safeguards; or
    • where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before any personal information are disclosed, if permitted by applicable laws.

Storing your personal information

Omni Bridgeway will store your personal information for as long as is necessary for the purposes for which it was collected, as explained in this privacy policy. However, once Omni Bridgeway believes the information is no longer required, we will undertake to remove any identifying details or destroy the information entirely.

In specific circumstances, we may store your personal information for longer periods of time if required under applicable law or so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

COOKIES

For more information about how our cookies work and information about how to manage your cookie settings please refer to our Cookie Policy at Annexure A of this Policy.

LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY

You may access or request correction of incorrect personal information that we hold about you by contacting us using the details at the Contact Us section of this Policy. We may take appropriate steps to verify your identity (or verify that you act as a legal guardian or authorised agent of the individual concerned) before granting a request to exercise a right in respect of your personal information.

We will respond in a timely manner to your requests and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date and complete. If we are unable to provide you with access to the information or if we cannot respond to other requests, we will provide you with reasons and inform you of any exceptions relied upon under applicable data protection laws. There will be some circumstances in which we are not required to give you access to your personal information or comply with your other requests. If we disagree with your correction request, we will annotate your personal information to indicate that a correction request was made.

We reserve the right to charge a reasonable fee where permitted by law, including where your request is manifestly unfounded or excessive (for example, photocopying costs or costs for our time spent in collating large amounts of material).

If European (including Swiss) data protection laws, or the DIFC Law, apply, there are additional rights available to you. In some cases, the availability of these rights depends on the legal basis we rely on to process your information (see above), as well as the applicability of exemptions under EU, Member State UK law, or the DIFC Law. The rights are as follows:

  • accessing your personal information and asking for a copy of it, including: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred;
  • correcting/updating or erasing your personal information;
  • restricting the processing of your personal information;
  • objecting to the processing of your personal information;
  • withdrawing consent for specific processing of your personal information;
  • if you have submitted personal information and you have given your consent or the information is required for the conclusion and/or the performance of the agreement with you, and if the information is processed by automated means: you are entitled to receive your personal information in a structured, commonly used and machine readable form and, if technically feasible, to transfer the personal information in that manner to another party at your request; and
  • lodging a complaint with your local data protection authority.

CCPA Rights. In general, California residents have the following rights with respect to their personal information:

  • Do-not-sell (opt-out): to opt-out of our sale of their personal information. We do not sell personal information about California residents, including those we have actual knowledge are younger than 16 years old, and have not done so in the prior 12 months.
  • Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions. 
  • Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):
    • categories of personal information collected;
    • categories of sources of personal information;
    • categories of personal information about them we have disclosed for a business purpose or sold;
    • categories of third parties to whom we have sold or disclosed for a business purpose their personal information;
    • the business or commercial purposes for collecting or selling personal information; and
    • a copy of the specific pieces of personal information we have collected about them.
  • Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA. 

Submitting CCPA Requests.California residents may submit CCPA requests to opt out of sales, to know (access) or to delete their personal information via the contact information set out in the Contact Us section below.

Where you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records for example by confirming your email address.  You must provide us with sufficient identification in order to verify your request.  In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.  Authorized agents may initiate a request on behalf of another individual by contacting us at [email protected]; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.   

Financial Incentives. If we may make available certain programs or offerings that are considered “financial incentives” under the CCPA, we will provide you with a description of the material terms of such program, so that you may choose whether or not you would like to participate in such programs.  We will not opt you in to any financial incentives without your consent, and you may subsequently opt out at any time.

CONTACT US

The members of the Omni Bridgeway Group who are the relevant regional data processors or controllers are listed below:

No. Name Registered Address
1 Omni Bridgeway Limited 68 Pitt Street Sydney, NSW, 2000, Australia
2 Omni Bridgeway (UK) Limited Suite 212, 81 Chancery Lane, London WC2A 1DD, United Kingdom
3 Omni Bridgeway (Singapore) Pte Limited & Omni Bridgeway Asia Pte Limited 6, #13-03, Battery Road, Singapore 049909, Singapore
4 Omni Bridgeway (USA) LLC C/o Corporation Service Company, 80 State Street, Albany NY 12207-2543, United States of America
5 Omni Bridgeway Capital (Canada) Limited Beck Robinson and Company, 700 – 686 West Broadway, Vancouver BC V5Z 1G, Canada
6 Omni Bridgeway BV Schiphol Boulevard 121, 1118BG Schiphol, the Netherlands
7 Omni Bridgeway AG Gereonstrasse 43-65, 50670 Cologne, Germany
8 Omni Bridgeway Advisory Ltd Unit 1905, Level 19 Index Tower Dubai International Financial Centre, PO Box 507152, Dubai, United Arab Emirates
9 Omni Bridgeway SA 4 Rue De La Rotisserie, 1204 Geneve, Switzerland

The primary point of contact for all issues arising from this Privacy Policy is our relevant regional Data Protection Officer for the entities listed above. The Regional Data Protection Officer can be contacted in the following ways:

EMEA

Germany:

Data Protection Officer: Simon Hochstein

Telephone:  +49 (0)221 80 11 55 - 18

Address: See above

Email: [email protected]

Netherlands, Switzerland, UK and UAE:

Data Protection Officer: Compliance and Contract Manager EMEA

Telephone: +31 70 338 4363

Address: See above

Email: [email protected]

North America:

Data Protection Officer: Chief Compliance Officer (CCO)

Address: See above

Telephone: 1800 252 5103 (toll free) or +(212) 488-5331

Email: [email protected]

APAC (including Singapore)

Data Protection Officer (Singapore): Singapore Data Protection Officer

Data Protection Officer APAC (other than Singapore): see contact details below

Address: See above

Telephone: Australia: 1800 016 464 (freecall within Australia) or +61 8 9225 2322.

                   Singapore: +65 6813 2647

Email: [email protected]

We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.

To contact your data protection supervisory authority

If you are unsatisfied with the outcome of your complaint you may ask the Privacy Officer to be referred to a higher authority within the company. Irrespective of the foregoing, you always have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement):

ANNEXURE A – COOKIE POLICY

We use certain cookies on our website. Some of them are essential to make our site work, others serve to provide you a better, faster and safer user experience and some provide us with statistical data by tracking users behavior on our website.

Cookies are small text files that are placed on your computer or mobile device by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide web services and functionalities for users. We use cookies to provide us with anonymous information on the use of our Website for analytics, to know what you find interesting on the Website and to deliver targeted advertising.

Most web browsers are set to accept cookies; however, you do not need to have cookies turned on to visit most of the Website. However, having cookies switched on should allow for a smoother and more tailored browsing experience, and is required for certain parts of the Website's functionality. In the majority of cases, a cookie does not provide us with any personal information.

Where we do process personal information through the cookies, we do so because this is necessary with a view to our legitimate interest in being able to operate our website and to offer a user-friendly website. The processing of personal information through Analytics cookies is based on your consent where this is required.  You may object to the above at this time via the following email address: [email protected].

Types of Cookies we use

Cookies may be either "persistent" cookies or "session" cookies. The Website uses both persistent and session cookies.

  • persistent cookie consists of a text file sent by a web server to a web browser, which allows us to collect and analyse (on an anonymous basis) traffic and use of the Website, monitor the system and improve operating performance, for example, store your preferences to enhance your subsequent visits. It will not be automatically deleted when the browser is closed but is stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date).
  • session cookie is essential to ensure the correct functioning of the Website and is used to manage registration/login and access to reserved features. It is stored temporarily during a browsing session will expire at the end of the user session, when the web browser is closed. The Website uses both persistent and session cookies.

A complete list of the cookies we use is set out in the table at the end of this policy. This list (together with the rest of this policy) is subject to change by Omni Bridgeway from time to time.

Other Tracking Technologies

  • Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Website and services to, among other things, track the activities of Website's visitors and users, help us manage content, and compile statistics about the Website's usage. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
  • Local Storage Objects. We may use HTML5 Local Storage Objects ("HTML LSOs") to store your Website preferences and to personalize your visit. HTML LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of HTML LSOs through your web browser.
  • Third Party Ad Networks. We use third parties such as network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy or cookies policy, not this one.
  • Third Party analytics. Our Website uses Google Adwords and Google Analytics, a web analytics service provided by Google, Inc. ("Google"). This enables us to evaluate usage of the Website, Google Analytics uses cookies (text files placed on your computer) to help website operators analyse how users use the site. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on website activity for website operators and providing other products relating to website activity and internet usage. The following data will be processed in connection with the use of Google Analytics:
    • Online identifiers (including cookie identifiers)
    • IP address
    • Device identifier
    • Type and version of browser
    • Operating system used
    • Referring URL (the website called up previously)
    • Time of the server request

    Google may also transfer this information to third parties where required to do so by law. Google is also entitled to commission subcontractors in the context of the processing of data on behalf of a controller.

    You can find a list of the subcontractors commissioned for the processing of data via the following link: https://privacy.google.com/businesses/subprocessors/index.html.Google will not associate your IP address with any other data held by Google.

    The information that has been processed will be stored for a period of 26 months and will be erased automatically once this retention period expires.

    Google cookies are governed by Google's privacy and/or cookies policy located at: policies.google.com/?hl=en. For more information on the treatment of user data by Google Analytics please refer to Google’s Privacy Policy retrievable at: https://support.google.com/analytics/answer/6004245?hl=en.

    You can also completely opt out of Google Analytics by using the links provided in the “Opting out of third party analytics” section below.

  • Pixels/Tags: Our website may also use a LinkedIn Insight Tag (unless you are a California resident, in which case we will not use a LinkedIn Insight Tag where you are browsing from an Californian IP address). The LinkedIn Insight Tag enables the collection of data regarding your visits to our website, including the URL, referrer, IP address, device and browser characteristics (User Agent), and timestamp. The IP addresses are truncated or hashed, and’ direct identifiers are removed within seven days in order to make the data pseudonymous. This remaining pseudonymized data is then deleted within 180 days.

     

    LinkedIn does not share the personal data with us, it only provides reports and alerts (which do not identify you) about our website audience and ad performance. LinkedIn also provides retargeting for visitors to our website, enabling us to show personalized ads off our website by using this data, but without identifying the member. Linkedin also uses data that does not identify you to improve ad relevance and reach you across devices. You can control the use of your personal data for advertising purposes through your browser settings on your computer or other device you’re using to access our services.

    You can also completely opt out of the Linkedin tag or other Linkedin analytics by using the links provided in the “Opting out of third party analytics” section below.

In order to be compliant with GDPR, we request consent for deploying analytics cookies, or advertising pixels/tags on our website where necessary.

Our Use of Cookies

We do not automatically capture or store personal information from browsers to the Website, other than to log your IP address (which in certain circumstances will be your personal data) and session information such as the duration of the visit to our site and the nature of the browser used. This information is used only for administration of the Website and in the compilation of statistics which we use for analysis in order to improve the Website and understand in general terms who uses our Website.

Cookies may be required to allow you to access and participate in certain areas of the Website. Once you have closed your browser, this type of cookie is deactivated. Like all cookies, you are able to remove or block particular cookies at any time (see below).

Your Cookie Choices

The majority of browsers will allow you to alter the settings used for cookies and to disable and enable them as you require.

You can reject all cookies (except strictly necessary cookies) in case you prefer not to receive them, and you can have your computer warn you whenever cookies are being used. You can delete the cookies that are already on your computer and you can set your browser to prevent them from being placed. Disabling cookies may, however, prevent some web services (including on the Website) from working correctly. Please be aware that when you have set your computer to reject cookies, it can limit the functionality of the Website and it is possible then that you will not have access to some of the features on the Website.

To disable cookies, or to receive a warning whenever cookies are being used, you have to adjust your browser settings. You can adjust your browser settings to delete certain cookies. Visit the "help" section of your browser for how to manage your cookie settings, or follow the links below:

Opting-out of Third Party Ad Networks.

You have the ability to opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Website or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.

Opting out of third party analytics.

If you do not wish to participate in analytics, click: https://omnibridgeway.com/website-policies/cookie-opt-out to opt out of marketing site analytics and opt-out of app site analytics. You can prevent the use of Google Analytics Cookies by adjusting the settings on your browser software, however, you may not be able to fully use all of the functions of the Website if you do so.

For more information about and to prevent Google’s collection of data generated by your use of this website (including your IP address) by downloading and installing a Browser Plugin available at https://tools.google.com/dlpage/gaoptout?hl=en. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit wikipedia.org, www.allaboutcookies.org, or www.aboutcookies.org.

LIST OF COOKIES USED

Performance Cookies
_ga This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.  By default it is set to expire after 2 years, although this is customisable by website owners.
_gat_UA-170599950-1 This is a pattern type cookie set by Google Analytics, where the pattern element on the name contains the unique identity number of the account or website it relates to. It is a variation of the _gat cookie which is used to limit the amount of data recorded by Google on high traffic volume websites.
_gid This cookie name is associated with Google Universal Analytics. It stores and updates a unique value for each page visited.
Linkedin Insight tag The LinkedIn Insight Tag is a piece of lightweight JavaScript code that enables campaign reporting and insights about website visitors. The Tag tracks conversions, retargets website visitors, and provides insights about website users interacting with our ads
Functionality Cookies
vuid This domain is owned by Vimeo. The main business activity is: Video Hosting/Sharing
Strictly Necessary Cookies
 
__cfduid Cookie associated with sites using CloudFlare, used to speed up page load times. It is used to override any security restrictions based on the IP address the visitor is coming from. It does not contain any user identification information.   
ASP.NET_SessionId    General purpose platform session cookie, used by sites written with Microsoft .NET based technologies. Usually used to maintain an anonymised user session by the server.
ARRAffinity This cookie is set by websites run on the Windows Azure cloud platform. It is used for load balancing to make sure the visitor page requests are routed to the same server in any browsing session.