Explore our comprehensive privacy policy to understand how we collect, use, and safeguard your personal information. We value your trust and are committed to transparency.
Disclaimer: A TL;DR ( Too Long Did not Read ) version will be provided under very long and complex sections. Summaries are provided for convenience and user-friendly understanding, but they are not legally recognized terms or sections. Always refer to the fully-written sections for official legal terms and use.
Welcome to the Twenty Third C Technology Limited (“Twenty Third C”) privacy policy. Twenty Third C respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Alternatively, you can download a pdf version of the policy here.
This privacy policy aims to give you information on how Twenty Third C collects and processes your personal data through your use of this website and / or any associated applications or platforms (including the use of 23C’s “nurama” (NURAMA.COM / ORAMA.IO) digital platform), including any data you may provide through this website and / or any associated applications or platforms (including via the “nurama” (NURAMAORAMA.IO) digital platform) when you access and view this website via any associated applications or platforms (including via the “nurama” (NURAMA.COM / ORAMA.IO) digital platform).
This website and / or any associated applications or platforms (including the “nurama” (NURAMA.COM / ORAMA.IO) digital platform) is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
TL;DR: This privacy policy explains how Twenty Third C collects and processes your personal data through their website, applications, and platforms, including the Orama digital platforms. The policy does not apply to children, and it is advised to read this policy along with any other privacy policies provided by Twenty Third C to understand how your data is used. This policy is meant to supplement other notices and privacy policies, not override them.
Twenty Third C is the controller and responsible for your personal data (collectively referred to as , "we", "us" or "our" in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
TL;DR: Twenty Third C is the controller and responsible for your personal data. They have a data privacy manager who can address any questions or requests regarding this privacy policy.
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.
TL;DR: To contact Twenty Third C regarding privacy policy or make a complaint, reach out to their data privacy manager via email or postal address provided.
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. 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 and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
TL;DR: This website includes links to third-party websites, and we are not responsible for their privacy policies. When you leave our site, it's recommended to review the privacy policies of the websites you visit..
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
TL;DR: We collect personal data, which is information that can identify you. This includes identity data (name, date of birth), contact data (address, email), financial data (bank account, payment card details), technical data (IP address, browser information), usage data (website activity), and marketing and communications data (marketing preferences).
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
TL;DR: We collect Aggregated Data that does not directly identify you and can use it for various purposes. We do not collect any Special Categories of Personal Data or information about criminal convictions and offenses.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
TL;DR: Failure to provide requested personal data may result in the inability to fulfill contracts or provide certain services.
We use different methods to collect data from and about you including through:
1. Direct interactions.
You may give us your Identity Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
2. Automated technology and Interactions.
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. [Please see our cookie policy [LINK] for further details.
3. Third parties or publicly available sources.
We will receive personal data about you from various third parties and public sources as set out below:
TL;DR: We collect personal data through direct interactions with you (such as filling out forms or contacting us), automated technology (like cookies and server logs), and from third parties or publicly available sources. This includes receiving data from analytics providers, technical/payment/delivery service providers, data brokers/aggregators, and public sources like Companies House and the Electoral Register.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
TL;DR: We use your personal data in accordance with the law, such as to fulfill contracts, pursue legitimate interests, comply with legal obligations, and with your consent for marketing communications. You can withdraw consent for marketing at any time.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
TL;DR: We use your personal data for various purposes, relying on different legal bases. The specific purposes and legal bases are described in the following table format. If you require further information on the legal basis for specific data processing activities, please contact us.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
TL;DR: We use your personal data to send you relevant marketing communications based on your interests and preferences, unless you have opted out.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, service experience or other transactions.
TL;DR: You can opt out of marketing messages at any time, but it won't affect personal data related to service purchases or other transactions.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
We will only use your personal data 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, please contact us.
If we need to use your personal data 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 personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
TL;DR: We use your personal data for the purposes we collected it, but if there is a need for a different purpose, we will notify you and explain the legal basis. In certain cases, we may process your data without your knowledge or consent as permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
TL;DR: We may share your personal data with external third parties in specific circumstances, such as business transactions. We ensure these parties treat your data securely and use it only for specified purposes as instructed by us.
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your 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:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
TL;DR: We may transfer your personal data to external third parties located outside the UK. When transferring data, we ensure it receives a similar level of protection. This includes transferring data to countries with adequate protection or using specific contracts approved for data transfers. Contact us for more information on the mechanisms used for transferring your personal data out of the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data 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.
TL;DR: We have strong security measures in place to protect your personal data from unauthorized access and breaches. We limit access to authorized personnel and have procedures to address any potential breaches.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are set out in the table Purposes for which we will use your personal data above.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
TL;DR: We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, as well as to comply with legal, regulatory, and reporting requirements. The retention period depends on various factors, including the nature of the data and any potential litigation. You have the right to request deletion of your data in certain circumstances. In some cases, we may anonymize your data for research or statistical purposes and use it indefinitely without further notice.
You have the rights to :
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us using the details set out above. No fee usually required.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
TL;DR: You have several rights regarding your personal data, including the right to access, correct, and delete your data. You can also object to processing, request data restriction, and data transfer. You can withdraw consent for processing, but this may affect certain services. No fee is usually required to exercise these rights, but a reasonable fee may be charged for unfounded or excessive requests.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no 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.
TL;DR: We may ask for specific information to confirm your identity and protect your personal data. This helps ensure that only authorized individuals can access your information. We may also contact you for additional details to expedite our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month 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.
Legitimate Interest
Means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
TL;DR: Legitimate Interest means we prioritize our business interests while considering the impact on your rights. We only use your personal data when our interests are not overridden unless we have your consent or legal obligations. For more information, contact us.
Performance of Contract
Means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation
Means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.