OB3 Privacy Policy (UK/EU)

Effective Date: 11 March 2026

Last Updated: 11 March 2026

This Privacy Policy applies to OceanBrowser Limited's (we, us, our) OB3 website and platform (the Platform) and should be read in conjunction with the Platform's Terms of Service.

By viewing and using this Platform you will be deemed to agree to this Privacy Policy. If you do not agree to this Privacy Policy, please stop using the Platform and contact us (see section "Contact Us" below) so we can discuss your concerns.

All capitalised terms that are used but not defined in this Privacy Policy will have the meaning given to them in the Terms of Service.

1. About Us

OceanBrowser Limited is a company registered in New Zealand (company number 9429035526476).

Our contact details:

We are the data controller for the personal data we process through the Platform. This means we determine how and why your personal data is processed.

UK/EU Data Protection: New Zealand has been recognized by the European Commission as providing an adequate level of data protection under the General Data Protection Regulation (GDPR). This means data can flow freely between the UK/EU and New Zealand.

2. Information We Collect

We collect and process the following types of personal data:

2.1 Personal Information You Provide

When you create an account or use the Platform, you provide us with:

User Content: Content you create or upload to the Platform (coursework, documents, comments, discussions, uploaded files) is not regarded as personal information for the purposes of this policy, but is governed by the User Content provisions in our Terms of Service.

2.2 Information Automatically Collected

When you use the Platform, our systems automatically collect:

2.3 Information from Third Parties

2.4 OB3 ID

When you create an account, you are assigned a unique identifier called an OB3 ID (a UUID). This OB3 ID is used to identify your work within the Platform and is particularly important if you choose to close your account (see Section 8).

3. Legal Basis for Processing

We process your personal data under the following legal bases:

3.1 Contract (GDPR Article 6(1)(b))

Processing is necessary to provide the Platform services to you under our Terms of Service. This includes:

3.2 Legitimate Interests (GDPR Article 6(1)(f))

We have legitimate interests in:

3.3 Consent (GDPR Article 6(1)(a))

Where required, we obtain your explicit consent for:

3.4 Legal Obligation (GDPR Article 6(1)(c))

We may process your data to comply with legal obligations, such as:

4. How We Use Your Information

We process and use your information for the following purposes:

4.1 Platform Services

4.2 Educational Purposes

If you are a student (Learner), we process your information to:

4.3 Platform Improvement and Analytics

4.4 Security and Compliance

4.5 Communications

4.6 Support Access

We have the ability to access your account for certain purposes, including:

This privileged access is restricted to authorized staff at OceanBrowser, and such access is logged. If you do not want OceanBrowser support staff to access your account under any circumstances, please email the Privacy Officer and you will be added to the support access opt-out list.

5. Data Sharing and Disclosure

5.1 Sharing Within Your Institution

If you are a student (Learner), we may share your information with:

5.2 Third-Party Service Providers

We share personal data with third-party service providers who help us operate the Platform:

Microsoft Azure (Web Hosting)

Amazon Web Services (File Storage)

DataStax Astra / IBM Cloud (Database)

Bunny CDN (Content Delivery Network)

Intercom Inc. (Customer Support)

5.3 Legal Requirements

We may disclose your personal data if required to do so by law or in response to:

5.4 Business Transfers

If we are involved in a merger, acquisition, sale of assets, or bankruptcy, your personal data may be transferred as part of that transaction. We will notify you of any such change and the choices you may have.

5.5 With Your Consent

We may share your personal data with other third parties when we have your explicit consent to do so.

6. International Data Transfers

6.1 Data Storage Locations

Your personal data is processed and stored in the following locations:

All of these locations are within the UK and European Union, providing a high level of data protection.

6.2 Access from New Zealand

OceanBrowser Limited is based in New Zealand, and our support and technical teams may access your data for operational purposes (such as providing support, maintaining the Platform, and investigating issues).

Transfer Safeguard: New Zealand has been granted an adequacy decision by the European Commission, meaning data transfers between the UK/EU and New Zealand are permitted as New Zealand is recognized as providing an adequate level of data protection.

6.3 Customer Support (Intercom - USA)

When you contact customer support, your support conversations are processed by Intercom Inc. in the United States. This transfer is protected by:

Important: Only support conversation data is transferred to Intercom. Your coursework, assessments, grades, and academic records remain in the UK/EU and are never shared with Intercom.

7. Data Retention

7.1 Active Accounts

We retain your personal data for as long as your account is active and you continue to use the Platform.

7.2 Academic Records

For students using OB3 as part of their studies:

If you are enrolled in a formal course of study, your course data may be retained for a period of years to comply with assessment and academic integrity requirements. This retention is necessary to support:

This means that even if you close your account (see Section 8), your academic records (coursework submissions, assessments, grades, feedback, and course activity) will be retained for the period required by your educational institution.

7.3 Alumni Access

If you are granted alumni access after completing a course, we will retain your data to provide ongoing access to course materials, subject to the provisions in our Terms of Service.

7.4 Closed Accounts

When you close your account (see Section 8):

7.5 Backups and Logs

We may continue to retain your personal information within Platform backups, logs, and secure record-keeping systems for:

Backups and logs are retained for limited periods and are securely destroyed when no longer needed. In the event of backup restoration, deleted personal information will be removed from the restored data.

7.6 Legal Requirements

We may retain data for longer periods if required by law, to resolve disputes, enforce our agreements, or protect our legal rights.

8. Your Rights Under GDPR

You have the following rights regarding your personal data:

8.1 Right of Access (Article 15)

You have the right to request a copy of the personal data we hold about you.

How to exercise this right:

The export will include:

To export or print your document content, open any document and click the "Viewer" button (top right). In the Viewer you can select and copy text, or print your document.

Response time: We will provide your data within 30 days of your request.

Download access: You will receive an email with a secure download link, valid for 14 days.

8.2 Right to Rectification (Article 16)

You have the right to correct inaccurate or incomplete personal data.

How to exercise this right:

8.3 Right to Erasure / Account Closure (Article 17)

You have the right to request deletion of your personal data, subject to certain exceptions.

Important for students: Due to educational compliance requirements, there are limitations on what can be deleted:

What WILL be deleted when you close your account:

What WILL be retained:

If you are a student using OB3 within a course of study, contributions you have made within your coursework will be retained.

Why academic records are retained: If you are enrolled in a formal course of study, your course data may be retained for a period of years to comply with assessment and academic integrity requirements. This is required for academic appeals, accreditation, degree verification, and compliance with UK/EU education regulations.

Your OB3 ID: After account closure, your retained academic records will be identified by your OB3 ID (a unique identifier) rather than your personal information.

How to exercise this right:

Response time: We will process your request within 30 days and send confirmation to your email address, including your OB3 ID for future reference.

Recommendation: Please download your data before closing your account, as you will no longer have access after closure.

8.4 Right to Data Portability (Article 20)

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transfer it to another service.

The data export described in Section 8.1 (Right of Access) fulfills this right. You will receive your data in formats that can be viewed and used.

8.5 Right to Object (Article 21)

You have the right to object to our processing of your personal data based on legitimate interests.

How to exercise this right: Email privacy.officer@oceanbrowser.com with details of your objection.

We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for legal claims.

8.6 Right to Restrict Processing (Article 18)

You have the right to request that we restrict processing of your personal data in certain circumstances (for example, while we verify the accuracy of data you've disputed).

How to exercise this right: Email privacy.officer@oceanbrowser.com

8.7 Right to Withdraw Consent (Article 7)

Where we process your data based on consent (such as for marketing communications), you have the right to withdraw that consent at any time.

How to exercise this right:

Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

8.8 Right to Lodge a Complaint

If you believe we have not handled your personal data properly, you have the right to lodge a complaint with a supervisory authority.

UK: Information Commissioner's Office (ICO) - https://ico.org.uk

EU: Your local data protection authority - https://edpb.europa.eu/about-edpb/board/members_en

We encourage you to contact us first at privacy.officer@oceanbrowser.com so we can try to resolve your concern.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

9.1 Security Measures

9.2 Your Responsibilities

You are responsible for:

9.3 Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will:

10. Cookies and Tracking Technologies

10.1 What are Cookies?

Cookies are small text files stored on your device when you visit the Platform. They help us provide and improve the Platform.

10.2 Types of Cookies We Use

Essential Cookies (Strictly Necessary):

These cookies are necessary for the Platform to function and cannot be disabled.

Analytics Cookies:

Functionality Cookies:

10.3 Third-Party Cookies

When you embed content from third-party providers (such as YouTube videos) by pasting URLs into the Platform, the embedded content may set cookies governed by that provider's privacy policy.

Avoiding third-party cookies: You can upload content directly to the Platform instead of embedding from third parties.

10.4 Managing Cookies and Consent

Cookie Consent:
When you first visit the Platform, you will see a cookie consent notice. You can choose to:

Your consent choices will be stored and you can change them at any time through the cookie settings link in the footer of the Platform.

Browser Controls:
You can also control cookies through your browser settings:

Contact us for specific advice on enabling OB3 cookies while disabling third-party cookies.

10.5 Do Not Track

Some browsers have "Do Not Track" features. We do not currently respond to Do Not Track signals, but we respect your privacy choices through the cookie controls described above.

11. Children's Privacy

The Platform is not intended for children under 13 years of age. We do not knowingly collect personal data from children under 13.

If you are under 13, please do not use the Platform or provide any personal information.

If we learn that we have collected personal data from a child under 13, we will delete that information as quickly as possible. If you believe we have collected information from a child under 13, please contact us at privacy.officer@oceanbrowser.com.

Note for educational institutions: If your institution enrolls students under 13 in courses using OB3, the institution is responsible for obtaining appropriate parental consent and ensuring compliance with applicable laws (such as COPPA in the US or local equivalents).

12. Third-Party Links and Embedded Content

The Platform may contain links to third-party websites, applications, and embedded content (such as videos, images, or interactive tools).

We are not responsible for the privacy practices of these third parties. When you click on a link or interact with embedded content, you may be subject to that third party's privacy policy.

We recommend reviewing the privacy policies of any third-party services you access through the Platform.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons.

13.1 Notification of Changes

When we make changes to this Privacy Policy, we will:

13.2 Your Continued Use

Your continued use of the Platform after we post changes constitutes your acceptance of the updated Privacy Policy. If you do not agree to the changes, please stop using the Platform and contact us to close your account.

13.3 Review Regularly

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:

Privacy Officer
OceanBrowser Limited
Email: privacy.officer@oceanbrowser.com
Address: 44 Melville Street, Dunedin 9016, New Zealand
Website: https://www.ob3.io

Response time: We will respond to your inquiry within 30 days.

For data subject rights requests (access, erasure, etc.), please see Section 8 for specific instructions.

15. Additional Information for UK/EU Users

15.1 Data Controller

OceanBrowser Limited (New Zealand company number 9429035526476) is the data controller responsible for your personal data.

15.2 Legal Framework

This Privacy Policy complies with:

15.3 New Zealand Adequacy

New Zealand has received adequacy decisions from both the European Commission and the UK, recognizing New Zealand's data protection laws as providing an adequate level of protection for personal data.

15.4 Representative

As we are based outside the UK/EU, we may be required to appoint a representative in the UK/EU. If appointed, contact details will be provided here.