Privacy Policy | VELLUM

Oxygene MCL’s VELLUM respects the privacy rights of our users and is strongly committed to protecting your privacy. This Privacy Policy applies to personal information collected through this web site (“this Site”) and other Oxygene MCL web sites and products or services provided by Oxygene MCL, including by providing a link to this Privacy Policy or otherwise displaying these terms.  Some of these sites include VELLUM, MOOLAH and Oxygene MCL.

Personal Information We Collect

Oxygene MCL, or where relevant a designated service provider, collects personal information through this Site, such as during registration, when you request certain services or products, or submit information to enter a sweepstakes, contest, or other promotion, or complete a survey or poll, which may include:

  • Your name, phone number, email address, work address, or other contact information
  • Signature, online identifier, Internet Protocol address, or other similar identifiers
  • Account login credentials (i.e. usernames & passwords), user content, usage information, browsing history, search history, and preferences
  • Professional, education, and employment related information (i.e. job title, professional background, etc.)

If you do not provide certain personal information, not all functionality on this Site will be available.

Personal Information is obtained directly from you, from others authorized to provide the information, such as from your employer or educational institution, from activity on this Site, and from other parties with whom we work, such as service providers, business partners, advertisers, advertising technology providers, and advertising servers. Do not provide information about others unless you are authorized to do so and you and those persons agree to have all information used, disclosed, and transferred in accordance with this Privacy Policy. By submitting the information about others, you represent and warrant that you are authorized to do so and that you have received authorization from the person about whom you are providing the information and that person has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy.

How We Collect and Use Your Personal Information

Oxygene MCL uses this information for carefully considered business purposes which also benefit our customers, and which include some or all of the following:

  • to provide and facilitate our products and services
  • to operate our services, products, and systems properly
  • to provide more relevant products and services
  • to communicate with you
  • to help Oxygene MCL improve, upgrade or enhance our products and services and develop new products and services
  • to provide support for our products and services, and for Oxygene MCL internal quality control purposes
  • to maintain the quality and safety of our products and services, and for internal quality control purpose including debugging to identify and repair errors that impair existing intended functionality
  • to provide you with offers and promotions about services and products of Oxygene MCL or of other parties that may be of interest to you
  • to enhance your experience with this Site, including to save your preferences and login information, and providing customized content
  • to analyze web site usage and analyze use of the Site
  • to identify and analyze product or service usage metrics and/or trends (e.g. pages visited, functions used, etc.) and develop data analysis, including for research, audit, reporting or other business operation purposes
  • to protect the interests, rights, safety, or property of Oxygene MCL or others and to monitor compliance with and enforce any terms of any agreement with Oxygene MCL
  • to monitor to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, and hold those responsible for that activity.

Additionally, some of our Sites have portions dedicated to a shared work space into which you may input your work product. Oxygene MCL does not use or disclose any contents of the work product that you input into the shared work space on this Site except to the extent you expressly permission us to do so on your behalf.

You may instruct Oxygene MCL at any time not to provide you with offers and promotions using your personal information collected in connection with the product you requested by clicking here. You can also update your settings for receiving offers and promotions from Oxygene MCL’s sites by clicking here.  Please also note that these processes may take some time to complete, consistent with applicable law. Please note that if you exercise choice in this manner, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information by you.

To assist us with the uses described in this privacy policy, information we or our designated service providers have collected about you through this Site, including your use of this Site, may be aggregated, analyzed or enhanced with personal or other information about you that we have from other sources.

Use of Cookies and Other Electronic Technologies

Oxygene MCL or a designated service provider may use “cookies,” web server logs, web beacons, or other electronic tools to collect information about you, such as your IP address, browser type, language, operating system, computer platform, and the state or country from which you accessed this Site. Oxygene MCL or a designated service provider may also use cookies, web server logs, web beacons, or other electronic tools to collect and compile statistical and other information about your use of this Site and other websites and the services provided on this Site, such as the web pages visited, the date and the time of your visit, the web sites you visited immediately before and after visiting this Site, the number of links you click within this Site, the functions you use on this Site, the databases you view and the searches you request on this Site, the data you save on or download from this Site, etc.

A cookie is a small text file placed on your computer. Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. The help function on most browsers contains instructions on how to set your browser to notify you before accepting cookies or to disable cookies entirely. However, note that this Site will not function properly if you disable cookies.

Oxygene MCL and its designated service providers may also place or recognize unique cookies on your computer or use other electronic tools in order to help display advertisements that you see on other websites. Information about your visits to, and activity on, this Site and other websites, an IP address, the number of times you have viewed an advertisement, and other such usage information is used, alone or in combination with other information, to display on your device screen advertisements that may be of particular interest to you. The use and collection of your information by these service providers is not covered by this Privacy Policy. 

Disclosure of Your Personal Information

Oxygene MCL may disclose the personal information it collects to our affiliates (including affiliated websites and other products under common ownership or control) and our designated service providers, including for the purposes set out in this Privacy Policy, including to the party who authorized your use of this Site, such as your employer or educational institution. Oxygene MCL may disclose to other third parties, including other users of this Site, information about your use of this Site and on this Site or other websites, but only in an aggregated and unattributed manner. Oxygene MCL may also share your personal information collected in connection with the product you requested with a sponsor or other third party (“Third-Party Providers”) that provides you with offers or promotions that may be of interest to you. You may instruct Oxygene MCL at any time not to share your personal information collected in connection with the product you requested with such Third Party Providers by clicking here.  Please note that (i) this process may take some time to complete, consistent with applicable law; and (ii) even after such process is completed, your personal information may continue to be shared with our affiliates (including affiliated websites and other products under common ownership or control) and designated service providers.

Oxygene MCL may also disclose your personal information to unaffiliated third parties if we believe in good faith that such disclosure is necessary to: (a) comply with any applicable law, rule or regulation or in response to a summon, court order, or other legal process; (b) protect the interests, rights, safety, or property of Oxygene MCL or others; (c) monitor compliance with and enforce any terms of service on this Site; (d) perform other activities related to such services and products, including billing and collection; (e) provide you with offers or promotions from Oxygene MCL; or (f) operate the systems that provide our services and products properly. In such an event, Oxygene MCL will use reasonable efforts to do the following:

  • Give the User reasonably prompt written notice of such requirement so that the User has an opportunity to comment thereon or object thereto and to preserve the confidential nature of the Customer Information and Personally Identifiable Information that Oxygene MCL is required to disclose.
  • At the User’s expense, use commercially reasonable efforts to cooperate with any of the User’s efforts to preserve the confidential nature of the Customer Information and Personally Identifiable Information that Oxygene MCL is required to disclose.

Please note, use and disclosure of personal information about former customers is governed by this Privacy Policy in the same manner as current customers. However, after the relationship ends, we may use such customer personal information less and less over time. Any personal information contained in Dockets will be treated consistent with the terms of this Privacy Policy.

The collection, further use, and/or disclosure of your information by Third-party Providers or by other third parties is not the responsibility of Oxygene MCL.  Rather, such collection, use, and/or disclosure is governed by the third parties’ privacy policies.

Accuracy, Security, and Retention of Your Personal Information

Any of your personal information collected by Oxygene MCL through this Site is kept on secure servers. Oxygene MCL uses security measures appropriate to the provision of the relevant product or service, such as reasonable administrative, technical, personnel, and physical measures to protect your personal information on such servers. To help us protect your privacy, you should maintain the secrecy of your username and password you set up in connection with your participation in this Site’s service, if any. Personal information is retained for as long as is necessary for the purpose for which it is collected, including legitimate business reasons, and/or legal and regulatory requirements.

Public Records

Certain databases available to registered users of this Site may contain personal information received from third party data suppliers. This personal information is contained in public records, publicly available information, and non-public information (collectively, “public records information”). Your use of this information is restricted to specific, legitimate purposes, and such information may not be used to violate any applicable laws, rules, or regulations.

Rights with Respect to Your Personal Information

Depending on the jurisdiction, you may have the right to access, correct, delete, or restrict use of certain personal information covered by this Privacy Policy. Depending on the jurisdiction, you may also have the right to request that we refrain from processing personal information. Please bear in mind that if you object this may affect our ability to provide our products and services. For inquiries about your personal information, please contact us by clicking here. While Oxygene MCL will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable laws. Please note that it may take some time to process your request, consistent with applicable law.

If you wish to access, correct, delete, or restrict use of your personal information contained in public records information, you will need to contact the third-party supplier of the information directly. If you have any questions regarding public records information on this Site, please contact our DPO at francis.monyango@oxygene.co.ke and include the name of the relevant website or product in the Subject line of your inquiry.

Transfer of Your Personal Information To Other Countries

Some of the uses and disclosures mentioned in this privacy policy may involve the transfer and processing of your personal information to and in various countries that may have different levels of privacy protection than your country. By using our products and services, you consent to such transfers and processing, including to and in Kenya. 

Links to Third-Party Web Sites

Oxygene MCL may provide links to third-party web sites. Since we do not control third-party sites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those web sites before providing any of your information on such sites.

Questions Regarding This Privacy Policy

If you have questions regarding this privacy policy, please contact us at our DPO at francis.monyango@oxygene.co.ke and include the name of the relevant web site or product in the Subject line of your inquiry.  If you have complaints about Oxygene MCL’s processing of your personal information, you may have the right to contact the applicable supervisory authority.

Modifications to This Privacy Policy

Oxygene MCL reserves the right to change this privacy policy at any time by posting revisions on this web page.

Such changes will be effective upon posting.

Contact Information

Questions or comments regarding this Statement should be submitted to our Data Protection Officer:

Francis Monyango

francis.monyango@oxygene.co.ke