Oxley Privacy Policy
Effective March 1, 2019
Welcome to Oxley’s Privacy Policy. Privacy and transparency are central elements of Oxley’s values and work, and we want you to understand what data we collect, store, and how we use it. If you have any questions or comments about our Privacy Policy, please contact us at info@oxley.agency. Oxley is committed to protecting your data and maintaining your privacy.
This Privacy Policy applies to all users of our Website(s), our mobile app(s) and any associated services (collectively, the “Services”).
1. Who we are
We are Oxley, a website design, development, and digital marketing company. Our main website address is: https://oxley.agency. In addition we also own and frequently use the website address https://oxleydev.com for development purposes.
We can be reached via e-mail at info@oxley.agency or you can reach us by telephone at (404) 507-6016.
Our postal address: Oxley Internet Solutions, LLC, 2256 Oakview Rd, Atlanta, GA 30317
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. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
2. Definitions
Service
Service means the websites oxley.agency, oxleydev.com, www.oxleyinternet.com, and mobile-applications operated by Oxley for the use of marketing its own business, and for the website design, development, and digital marketing services provided by Oxley to its clients.
Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small files stored on your device (computer or mobile device).
3. Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
3.1 Types of Data Collected
a) Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Cookies and Usage Data
b) Usage Data
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
c) Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
3.2 Use of Data
Oxley uses the collected data for various purposes:
- To provide and maintain the Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer care and support
- To provide analysis or valuable information so that we can improve the Service
- To monitor the usage of the Service
- To detect, prevent and address technical issues
4. Contact Forms
When contact forms are submitted, the data is sent to the appropriate recipient. This data is only shared with the intended recipient of the form submission and is only used for customer service purposes with the submitter of the form. This data is not used for marketing purposes.
5. Comments
When visitors leave comments on our site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
6. Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.
7. Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
8. Email Marketing
We collect the e-mail addresses of those who communicate with us via e-mail, the e-mail addresses of those who make postings to our chat areas, customer information from a product purchase, information volunteered by the consumer, such as survey information and/or site registrations.
The information we collect is used by us to contact consumers for marketing purposes, disclosed when legally required to do so, at the request of governmental authorities conducting an investigation, to verify or enforce compliance with the policies governing our Website and applicable laws or to protect against misuse or unauthorized use of our Website, to a successor entity in connection with a corporate merger, consolidation, sale of assets or other corporate change respecting the Website.
9. Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
9.1 Google Analytics
We use Google Analytics on our website. This is an analytics service provided by Google, Inc. (“Google”). A cookie is used to collect the information generated of your use on our website (including IP Address). Your information is sent and stored on Google servers, and this information is used by Google to generate reports. These reports are used to evaluate your use and activity on our website, as well as internet usage and other services related to the website activity. Google will not use your IP and associate it with any other Google held related data. Your information may also be transferred by Google to third parties where required by law, or third parties that process the data for Google. For more information pertaining to Google’s privacy policy, it can be viewed here: https://policies.google.com/privacy.
If you’d like to opt-out of google analytics for the web, please visit Google Analytics Opt-out Browser Add-on.
9.2 Facebook conversion pixels
We use the “Custom Audience pixel” of Facebook Inc. (“Facebook”) on our website. With its help, we can keep track of what users do after they see or click on a Facebook advertisement. This enables us to monitor the effectiveness of Facebook ads for purposes of statistics and market research. Data collected in this way is anonymous to us, which means we cannot see the personal data of individual users. However, this data is saved and processed by Facebook. Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and outside of Facebook. A cookie can also be saved on your device for these purposes.
Please click here if you would like to withdraw your consent https://www.facebook.com/settings/?tab=ads#_=_
9.3 Google Tag Manager (GTM)
Google Tag Manager (GTM”) is a tag management system to manage JavaScript and HTML tags used for tracking and analytics on websites. Tags are small code elements that, among other things, are used to measure traffic and visitor behavior: to understand the effect of online advertising and social channels; to set up remarketing and orientation towards target groups; and to test and optimize websites. GTM makes it easier for us to integrate and manage our tags. We use GTM on our website to include the following tracking tools (as in described in detail this Section 9):
- Google Analytics
- Facebook Conversion Pixels
- Twitter tailored audience
If you have performed deactivation, GTM takes this deactivation into account. For more information about GTM’s privacy practices can be found at https://policies.google.com/privacy?hl=en and terms of use at https://www.google.com/analytics/tag-manager/use-policy/.
9.4 Twitter tailored audience
We use the tool Tailored Audiences of Twitter Inc., www.twitter.com (“Twitter”), used to target existing users and customers to create remarketing campaigns. Targeting activity can include directly reaching out to users or visitors to the Oxley website and campaign pages and/or retargeting previous customer lists. Twitter has set a minimum size limit for a tailored audience to 500 users to protect anonymity. If the tailored audience does not match 500 Twitter users, it will display as “audience too small” and is not available for targeting. Details about Twitter’s policies for conversion tracking and tailored audiences can be found at https://business.twitter.com/en/help/ads-policies/other-policy-requirements/policies-for-conversion-tracking-and-tailored-audiences.html.
9.5 Google Fonts
For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.
For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our plugin. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.
If your browser does not support web fonts, a standard font is used by your computer.
Further information about handling user data, can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy at https://www.google.com/policies/privacy/.
9.6 Urchin Tracking Module (UTM)
UTM tags are not tools, but work as a custom URL for marketing campaigns and reports can be viewed in platforms like Google Analytics. UTM tags are appended as part of the visible URL in order to allow marketing programs to understand the specific instance of a link. UTM tag reports are observed in Google Analytics/Mail Chimp for understanding visitors to our website – for example, if they have visited the website, clicked on a link or signed up to a conference/event. These details are collected at an aggregated level. By customizing the URL with a UTM tag, it allows us to better understand the marketing activity, which then allows us to more effectively serve our audience.
The tracking occurs via the UTM parameters that are appended in the URL. When a user clicks an UTM tagged URL, based on the parameters set, we will be able to track from which end source the user has interacted with that URL.
10. Transfer Of Data
Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Oxley will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
11. Retention Of Data
Oxley processes and stores your personal data only for the time necessary to achieve the stated purpose (unless otherwise stated in this Privacy Policy) and as permitted under the applicable laws or regulations.
As soon as the purpose for data storage is achieved, or the appropriate term of storage provided for by any applicable laws or regulations expires, your personal data will be deleted consistent with this and any other applicable Oxley policies (e.g., document retention and/or records management policy) unless your personal data are required for the formation of or performance under a contract.
11.1 What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
12. Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
13. Disclosure Of Data
Legal Requirements
Oxley may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Oxley
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
As an European citizen, under GDPR, you have certain individual rights. You can learn more about these rights on the GDPR Website.
14. Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
15. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.