Privacy Policy
1. Introduction
1.1 Offmon Limited is committed to safeguarding the privacy of individuals whose personal data is processed in the course of our business and through the platform we operate.
1.2 This policy explains the personal data we process, the purposes for which we process it, the legal bases on which we rely, and the rights available to data subjects. It applies in different ways depending on the personal data concerned and the role in which Offmon Limited is acting — see Section 4.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.4 In this policy, "we", "us" and "our" refer to Offmon Limited. For more information about us, see Section 19.
2. Who and what this policy covers
2.1 This policy provides information about personal data processed by Offmon Limited in the following contexts:
(a) when you visit or interact with our website at
Offmon ;
(b) when you are an existing or prospective customer of Offmon Limited, or an individual contact at such a customer, and we communicate with you or process your data in connection with the supply of our services to your organisation; and
(c) where Offmon Limited acts as a data processor on behalf of a police force or probation service in connection with the operation of the Offmon platform — see Section 4.3 and Section 15.
2.2 This policy does not constitute the primary privacy information that a police force or probation service is required to provide to a monitored individual or to any other person whose personal data is processed under that authority's monitoring activities. That information is provided by the relevant authority. See Section 15.
3. About the Offmon platform
3.1 Offmon Limited develops and operates the Offmon platform: software licensed to United Kingdom law enforcement agencies and probation services for use in the supervision of individuals subject to Sexual Harm Prevention Orders, licence conditions, or equivalent statutory measures.
3.2 The platform's purpose is to support the lawful and proportionate supervision of monitored individuals by identifying activity that may be relevant to the conditions of their supervision and surfacing it to authorised personnel of the responsible authority for review.
3.3 Further information about the platform, the role of Offmon Limited in connection with it, and the data protection framework that applies, is provided at Section 15.
4. Our roles: data controller and data processor
4.1 Offmon Limited acts in two distinct roles depending on the personal data concerned. The legal regime that applies, and the rights that data subjects may exercise, differ accordingly.
4.2 When we are the data controller. In respect of personal data of visitors to our website, of prospective and existing corporate customers, of individual contacts at those customers, and of other persons who interact directly with our own business operations, Offmon Limited is the data controller. This processing is governed by the United Kingdom General Data Protection Regulation and Part 2 of the Data Protection Act 2018. Sections 5 to 14 (inclusive) of this policy describe this processing.
4.3 When we are the data processor. In respect of personal data processed through the Offmon platform for the supervision of monitored individuals — including data captured from monitored devices and case management data held within the platform's web-based interface — the law enforcement agency or probation service deploying the platform is the data controller, and Offmon Limited is the data processor acting on the controller's documented instructions. This processing is governed by Part 3 of the Data Protection Act 2018 (law enforcement processing) and is not governed by UK GDPR. Section 15 of this policy provides further information.
4.4 If you are a monitored individual, or if you believe your personal data has been processed through the Offmon platform other than through your direct interaction with our website or our business operations, the appropriate point of contact for information about that processing and for the exercise of your rights is the law enforcement agency or probation service responsible for the relevant supervision, not Offmon Limited. Further information is provided at Section 15.
5. How we use your personal data
5.1 In this Section 5 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
This section addresses processing in which Offmon Limited is the data controller (see Section 4.2). Processing in which Offmon Limited is a data processor is addressed at Section 15.
5.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
5.3 We may process your account data ("account data"). The account data may include your name, email address, telephone number and employment details. The source of the account data is you or your employer. The account data may be processed for the purposes of providing our services, ensuring the security of our services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.
5.4 We may process information that you post for publication through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our services. The legal basis for this processing is consent.
5.5 We may process information contained in any enquiry you submit to us regarding our services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling our services to you. The legal basis for this processing is consent.
5.6 We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent.
5.7 We may process information relating to transactions, including purchases of our services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your bank account details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our services and business.
5.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
5.9 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our services and business and communications with users.
6. Providing your personal data to others
6.1 We may disclose your personal data to our professional advisers and/or insurers insofar as reasonably necessary for the purposes of obtaining professional advice, obtaining or maintaining insurance coverage, managing risks, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6.2 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for maintaining or developing our services.
6.3 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
6.4 In addition to the specific disclosures of personal data set out in this Section 6, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. International transfers of your personal data
7.1 In this Section 7, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom. This Section does not apply to personal data processed through the platform under our processor role; the data residency position for that processing is set out at Section 15.11.
7.2 The hosting facilities for our services are situated in the United Kingdom.
7.3 Any suppliers or subcontractors who help to maintain or develop our services are situated in the United Kingdom, Spain and Tunisia.
8. Retaining and deleting personal data
8.1 This Section 8 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
8.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
8.3 Notwithstanding the other provisions of this Section 8, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
9. Security of personal data
9.1 We take appropriate technical and organisational precautions to secure personal data and to prevent the loss, misuse or alteration of personal data, applying measures proportionate to the sensitivity of the data and the risks of the processing.
9.2 We store personal data on secure servers, personal computers and mobile devices.
9.3 Passwords are stored by us in encrypted form.
9.4 Data that is sent from your web browser to our web server, or from our web server to your web browser, is protected using encryption technology.
9.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
9.6 You should ensure that any password you use to access our services is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our services confidential and we will not ask you for your password (except when you log in to our services).
9.7 Further information on the technical and organisational measures applied to monitoring data processed through the platform is provided at Section 15.10.
10. Amendments
10.1 We may update this policy from time to time by publishing a new version on our website.
10.2 We may notify you of significant changes to this policy by email.
11. Your rights
11.1 This Section 11 summarises the rights available under data protection law in respect of personal data for which Offmon Limited is the data controller. Some of these rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. The rights of monitored individuals and other persons whose personal data is processed through the platform under our processor role are exercised against the relevant data controller — see Section 15.8.
11.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
11.3 You have the right to confirmation as to whether or not we process your personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
11.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
11.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
11.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
11.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
11.8 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
11.9 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In the United Kingdom this is the Information Commissioner's Office.
11.10 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
11.11 You may exercise any of your rights in relation to your personal data by written notice to us.
12. Third party websites
12.1 Our website and services include hyperlinks to, and details of, third party websites.
12.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
13. Personal data of children
13.1 Our website and the corporate services described in Section 5 are not directed at, and we do not knowingly collect personal data of, persons under the age of 16 in those contexts.
13.2 If we have reason to believe that we hold personal data of a person under that age in connection with our website or corporate services, we will delete that personal data.
13.3 This Section 13 addresses our controller activities only. The age and circumstances of monitored individuals are matters for the police force or probation service responsible for the relevant supervision.
14. Updating information
14.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
15. Processing on behalf of law enforcement agencies and probation services (monitoring activity)
15.1 Offmon Limited operates the Offmon platform, which is licensed to and deployed by United Kingdom law enforcement agencies and probation services for the supervision of individuals subject to Sexual Harm Prevention Orders, licence conditions, or equivalent statutory measures. In this Section 15, those law enforcement agencies and probation services are referred to collectively as "supervising authorities", and an individual subject to such supervision is referred to as a "monitored individual".
15.2 Where personal data is processed through the platform as part of the supervision of a monitored individual, or as part of any related operational activity carried out by a supervising authority through the platform, the supervising authority is the data controller in respect of that personal data. Offmon Limited acts solely as a data processor on the supervising authority's behalf. Our obligations as processor are set out in the data processing terms agreed between Offmon Limited and each supervising authority.
15.3 Processing of monitoring data by a supervising authority is conducted under Part 3 of the Data Protection Act 2018 (law enforcement processing). The lawful basis for that processing is determined by the supervising authority and is grounded in the statutory powers, court orders or licence conditions that apply to each monitored individual. Such processing is not based on the consent of the monitored individual.
15.4 The platform comprises:
(a) mobile applications installed on the monitored individual's device by arrangement with the supervising authority, which carry out text monitoring on monitored devices, image analysis on monitored devices, and screenshot capture on monitored devices, with the specific functions available depending on the device platform;
(b) a network configuration applied to the monitored individual's device which enables monitoring of domain name queries from monitored devices; and
(c) a secure web-based interface used by authorised personnel of supervising authorities to review alerts, manage cases, and configure monitoring within the platform.
15.5 Access to the platform is credential-gated. The mobile applications and the web-based interface cannot be used by any person without credentials issued under the authority of a supervising authority. Members of the public who download a mobile application from a public application store are unable to authenticate to it or otherwise use it.
15.6 Where activity on a monitored device indicates a matter relevant to the conditions of supervision, that activity is recorded and made available to the supervising authority for review by authorised personnel. Other content is not retained.
15.7 The platform is designed to detect and report, not to block or otherwise interfere with the operation of the monitored device. It does not impose restrictions on the use of the monitored device beyond those imposed by the supervising authority through other means.
15.8 The supervising authority is responsible for providing monitored individuals — and any other persons whose personal data may be processed in connection with the supervision — with information about that processing, including its purpose, lawful basis, retention, and the rights available under Part 3 of the Data Protection Act 2018. Where any such person wishes to obtain information about, or exercise rights in relation to, personal data processed through the platform, the request should be made to the supervising authority responsible for the relevant supervision. Offmon Limited will assist supervising authorities in responding to such requests in accordance with our processing obligations and applicable law.
15.9 Personal data of third parties may be incidentally processed through the platform — for example, where a third party's image, text, or device interaction appears on a monitored individual's device. Such incidental processing forms part of the supervising authority's processing for law enforcement purposes and is subject to the same controller responsibilities and rights framework described in this Section 15.
15.10 We apply technical and organisational measures to protect monitoring data processed through the platform. These include encryption of sensitive content from the point of capture on the monitored device through to its retrieval by authorised personnel of the supervising authority, segregation between supervising authorities such that no supervising authority has access to another's data, strict controls on access by Offmon personnel to data within the platform, and an information assurance posture aligned with the United Kingdom National Cyber Security Centre's Cloud Security Principles. Further detail on these measures is provided to supervising authorities under our procurement and information assurance documentation.
15.11 All hosting and processing of monitoring data, and of the platform infrastructure that supports it, takes place within the United Kingdom. We do not transfer monitoring data to any country outside the United Kingdom.
16. About cookies
16.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
16.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
16.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
17. Cookies that we use
17.1 We use cookies for the following purposes:
(a) authentication — we use cookies to identify you when you visit our services and as you navigate our services;
(b) status — we use cookies to help us to determine if you are logged into our services;
(c) security — we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
(d) analysis — we use cookies to help us to analyse the use and performance of our website and services; and
(e) cookie consent — we use cookies to store your preferences in relation to the use of cookies more generally.
18. Cookies used by our service providers
18.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
18.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: Privacy Policy – Privacy & Terms – Google .
19. Our details
19.1 This website is owned and operated by Offmon Limited.
19.2 We are registered in Scotland under registration number SC843783, and our registered office is at 8 Deer Park Avenue, Livingston, United Kingdom, EH54 8AF.
19.3 Our principal place of business is at 8 Deer Park Avenue, Livingston, United Kingdom, EH54 8AF.
19.4 You can contact us:
(a) using our website contact form; or
(b) by email, using hello@offmon.com.