Effective date: 18/09/2023

Whether you use OurCal, visit our website, speak to one of our team or use our services more widely, you are trusting us with your information. When you use the OurCal app, your profile, groups, calendars, events, and messages are all encrypted with end-to-end encryption (E2EE). This means that only you and the intended recipients of these can view them. This policy sets out how we collect, use and respect such information, and how the law protects you and your information.

This privacy policy explains how we collect and process your information. Please read it together with any other data protection documents we may have sent you. This policy supplements other such documents and is not intended to override them. All references to information in this policy, means any data which identifies a natural person or which allows that person to be identified when combined with other data.

This privacy policy is provided in accordance with our obligations under applicable privacy and data protection law, including the UK retained version of Regulation (EU) 2016/679 (GDPR) and the Data Protection Act 2018.

We keep our privacy policy under regular review. The version of the policy became effective on the date shown above. To make any revisions clear to you, we host this policy on GitHub as well as its previous versions and the changes between them.

We collect and use information to deliver our services via the OurCal app, to run our business, to operate our website, as well as to provide useful updates and other information about our apps, products and services. In this context, we are a data controller.

We have set out below the information we may collect, use, store and transfer:

• Contact data including your email address.
• Data needed for your OurCal account which is your unique user identifier and email address.
• Your profile, groups, calendars, events, and messages metadata such as when they were created and with what other account user identifiers.
• Your content including your profile, groups, calendars, events, and messages sent and shared via the OurCal app. This data is E2EE and can't be seen by us or anyone other than the sender and intended recipients. Since it is E2EE, it can't be used to identify you, so is not personal data.
• Technical data including information about the device you use to install, access or use our services and the OurCal app as well as to use our website, the device model, operating system, app version, your browser type and version, mobile operator, internet service provider, language, time zone setting and estimated geographic location, browser plug-in types and versions.
• Authentication information required to use the OurCal app.
• Usage data including information about your visit, including the website that referred you to our website (if applicable), the path that you take through and from our website (including date and time); pages that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
• Marketing and communications data including preferences in receiving marketing from us and communication preferences.
• Aggregated data such as technical and analytical data. Aggregated data may be derived from your information but is not considered ‘personal data’ in law as it does not reveal your identity. However, if we combine or connect such data with your information so that it can directly or indirectly identify you, we will apply this policy to such combined data.

We use different methods to collect data including through:

• Information you provide to us directly.
• Automated technologies or interactions. This may include information about your use of our services, how you interact with other users, information about your device, troubleshooting and diagnostic information.
• Third parties and publicly available sources. We may receive personal data from various third parties such as:
  • technical data from analytics and crash reporting providers

Our services are not intended for children and we do not knowingly collect information on children below the age of 13.

We will only collect and use information when the law allows us to. Most commonly, we will use your information so we can provide our services, for marketing and if required by law. See below for further details

The information below sets out the ways we use information and our legal basis for doing so. Most commonly, we will use your information:

• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is in our legitimate interest to do so (or those of a third party) and it is proportionate to do so;
• where you provide your consent;
• where we need to comply with a legal obligation.

• your contact data including your email address
• your content
• usage information
• account access information
• authentication information
• device information

• help you get your OurCal account set up
• ensure the service is running properly and perform troubleshooting
• maintain security
• link a device to your account
• to send and receive groups, calendars, events, and messages
• to show other OurCal users belonging to the same group your profile

• usage information
• account access information
• device information

• to establish business intelligence about how users use our OurCal app and our services
• to count the number of users of our OurCal app
• to improve our service offering and develop our OurCal app

• content you share on the OurCal app
• your device's calendar events

You have the right to withdraw your consent to use this information.

• to send and receive messages and events
• to show you and let you edit your device's calendar events in the OurCal app

• your contact data including your email address
• your content
• usage information
• account access information
• authentication information
• device information

• to comply with requests from regulators, law enforcement or others who are legally entitled to the information
• to comply with court orders in civil or criminal actions
• to comply with regulatory obligations

Where we need to collect information by law, or under the terms of a contract and you do not provide that information when requested, we may not be able to perform the contract or provide you with our services.

We will only use your information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, contact us.

If we need to use your information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may share your information with others, particularly those that help us provide our services or run our business effectively. For example, we will share your data with the services (such as Seald, Stream, and Google Firebase) that provide the respective E2EE, messaging, and authentication functionality incorporated in the OurCal app. In addition, we share data with our staff, our IT service providers, those who manage our data, and our advisers and marketing partners.

We require others to respect the information we share with them, and to only use it in ways the law allows. We only allow others to use such information for the specific purposes we set out, and not for any other purposes. When we engage processors to process information on our behalf, we ensure a contract is in place with the processor that sets out the details of the processing.

See below for further details

We may have to share information with third parties (including those below) for the purposes and activities explained above:

• Our staff and who provide services or are involved in the running of our business.
• Service providers who perform services and functions on our behalf in connection with the operation of our app and business such as software and application service providers and third parties who host, store and manage data or provide programming or technical support, etc.
• Professional advisers including our accountants, insurers and brokers, etc.
• Analytics partners to analyse website traffic and understand customer needs and trends.
• Marketing service providers to help us to communicate with you.
• If we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our websites or customers.
• Those to whom we may sell, transfer, or merge parts of our business with, or where we acquire other businesses or merge with them. If such a change happens then any new owners may use your personal data in the same way as set out in this policy.

We will share information, without notice, only if we are required to do so by law or we, in the good faith, believe that such action is necessary to:

• comply with legislation or any legal process served on us;
• protect and defend our rights and/or property; and
• to protect personal safety.

We will not sell or give your information to third parties for them to contact or market their goods or services to you.

The third parties we send information to may be based outside the UK. If they are, their use of your information will involve a transfer of data outside the UK. Whenever we transfer personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer information to countries that have been deemed to provide an adequate level of protection for personal data by the Information Commissioner’s Office. For further details, see the Information Commissioner’s Office website.
• Where we use certain service providers, we may use specific contracts approved by the Information Commissioner’s Office with the service provider which give the information the same protection it has in the UK. For further details, see the Information Commissioner’s Office website for the transfer of personal data to third countries.

Analytics providers. We use Plausible, Branch, and Mixpanel on both our website & app which are configured to or by default do not collect any personal data or use cookies.

Our website may include links to third-party websites and/or plug-ins. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or services and are not responsible for their privacy practices or privacy statements. When you leave our website, we encourage you to read the privacy policy of any new website you visit if this a concern for you.

We take steps to keep your information secure and we delete it when we no longer need it.

See below for further details

OurCal provides E2EE for your profile, events, and messages. This data is only ever stored on our servers in its encrypted, ciphertext form.

We have put in place appropriate security measures to prevent your contact information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to that information to those of our staff and other third parties who have a business need to know. They will only process information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will retain information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Privacy laws give you certain rights. For example, you can choose whether to receive marketing from us and you can ask us what information we have about you.

See below for further details

You may, at any time opt-out of receiving marketing communications from us by contacting us or selecting the unsubscribe option in any e-mail from us.

You have the right to:

• Request access. This means you can ask us to give you a copy of the information we hold about you.
• Request correction. This means if we have incomplete or inaccurate information, you can ask us to correct it. It is important that the information we hold about you is accurate and current. Please keep us informed if the information you provide us changes as our relationship evolves. Note, we may need to verify the accuracy of the new data you provide to us.
• Request erasure. This means you can ask us to delete or remove any information we have if there is no good reason for us continuing to have it. You also have the right to ask us to delete or remove information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing. This means you can contact us if you feel our use of your information impacts on your rights and freedoms. This applies if we are: (a) relying on our legitimate interest (or those of a third party) to use your information; (b) if we are using your information for direct marketing purposes; (c) if you believe we are using your information unlawfully; or (d) where we need to erase you information to comply with local laws. It is unlikely, but in some cases we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction. This means you can ask us to suspend using your information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer. This means you can ask us to transfer the information we hold on you to you, or to a third party. We will provide to you, or the third party you have chosen, your information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
• Withdraw consent. This means you can tell us that you no longer consent to our use of your information at any time where we are relying on consent to process your information. If you withdraw your consent, we may not be able to provide certain services or content to you. We will advise you if this is the case at the time you withdraw your consent. Note that this will only apply to any information where we were previously relying on consent as the legal basis to use your information. This action will also not affect the lawfulness of any processing carried out before you withdraw your consent.

We may need to request specific information from you to help us confirm your identity and your rights in relation to your request. This is a security measure to ensure that information is not disclosed to any person who does not have a right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to exercise the rights listed above. However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests as soon as reasonably practicable and at least within one month. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you have any questions or would like to contact us about this policy, you can contact us by email at hi@ourcal.com.

We are Onin Ltd. Our business is registered in England with company number 11941893 and our registered office is 128 City Road, London EC1V 2NX.