2. If you are an existing customer of ours, further details about how we use your personal information is set out in your customer contract with us. Further notices highlighting certain uses we wish to make of your personal information together with the ability to opt in or out of selected uses may also be provided when we collect personal information from you.
3. The Website may contain links to other third party websites (for instance, for registration purpose to events organized by third parties). If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.
- Personal information collection.
- Usage of personal information.
- Protection of personal information.
- Rights to prevent marketing and to access and update your personal information.
- Cookies Policy.
Information we may collect about you
We will collect and process all or some of the following personal information about you:
The personal information that you provide to us such as when you complete a form on our Website, including but not limited to, your name, email address, phone number, country and company (and/or the industry your work in). We may also process information on your education and work experience in connection with a job opening at XPay.Life for which you wish to be considered. You may also provide us with your contact details, address and bank details to enable us to perform a contract you have entered into with us or to make payments to you in relation to goods or services you provide to us
Correspondence and other communications if you contact us by telephone, letter or by email, we will typically keep a record of that correspondence or communication
Website and communication usage details of your visits to the websites and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, browser language, access time, traffic data, location data, web logs, movements on the website, referring web site addresses and other communication data. We may also collect information about the pages you view within the Website and other actions you take while visiting us. In addition, we may also use such technologies to determine whether you’ve opened an e-mail or clicked on a link contained in an e-mail.
Information from third parties we may also be provided with your information from other sources, for example from our affiliate companies or business partners in relation to business opportunities or from search engines, credit reference companies or government agencies, in relation to our due diligence processes.
Use of your personal information
In this section, we set out the purposes for which we use personal information that we collect and hold and, in compliance with our obligations under European law, identify the “legal grounds” on which we rely to process the information.
These “legal grounds” are set out in European data protection law, which allows companies to process personal data only when the processing is permitted by the specific “legal grounds” set out in the law
Please note that, in addition to the disclosures we have identified below, we may disclose personal information for the purposes we explain in this notice to service providers, contractors, agents, advisors (e.g. legal, financial, business or other advisors) that perform activities on our behalf.
- To communicate effectively with you and conduct our business, including to fulfil your requests to respond to your contact request, your registration request to events organized by XPay.Life or your appointment request with one of our experts, to respond to your request for proposal or offer if you are interested in doing business with us or we may contact you if we are interested in doing business with you, to respond to your job application, to otherwise communicate with you and/or with other internal and external parties concerning you, or to carry out our obligations arising from any agreements entered into between you and us.
Use justification: contract performance, legitimate interests to enable us to perform our obligations and provide our services to you.
- To provide you with access to restricted Website areas to provide you with an online account and access to restricted areas, where you have filled in a form to create an account on our Website.
Use justification: contract performance.
- To provide you with marketing materials to provide you with email alerts, updates, offers and invitations to XPay.Life events, where you have chosen to receive these. We may also use your information for marketing our own and our selected business partners’ products and services to you by [post, email, SMS, phone and fax] and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in the “Contacting Us” section below.
Use justification: consent, legitimate interest to keep you updated with news in relation to our products and services.
- For research and development purposes to analyse your personal information in order to better understand your and our other clients’ services and marketing requirements, to better understand our business and develop our products and services;
Use justification: legitimate interests to allow us to improve our services.
- To personalize your experience on our Websites to collect statistics about our Websites’ usage and effectiveness through the use of various technologies, and personalize your experience while you are on our Websites, as well as tailor our interactions with you.
Use justification: consent, legitimate interest to improve your user experience.
- To inform you of changes to notify you about changes to our services and products;
Use justification: legitimate interests to notify you about changes to our service.
- To ensure Website content is relevant to ensure that content from our Websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers;
Use justification: legitimate interests (to allow us to provide you with the content and services on the Website.
- To reorganise or make changes to our business in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your personal information to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this policy
Use justification: legitimate interests in order to allow us to change our business.
- In connection with legal or regulatory obligations, we may process your personal information to comply with our regulatory requirements or dialogue with regulators as applicable, which may include disclosing your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted and feasible, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
Use justification: legal obligations, legal claims, legitimate interests to cooperate with law enforcement and regulatory authorities.
Transmission, storage and security of your personal information
In order to fulfil your requests, we may need to share or otherwise transfer your personal information within the XPay.Life such as to the Sales, Communication or Marketing teams based in your country or relevant for your industry sector. Where appropriate we may also transfer your personal information to third parties, for example external event organizers or partner companies who may be in a better position to satisfy your request.
Security over the internet
No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.
All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.
Export outside the EEA
Where we transfer personal information from inside the European Economic Area (the EEA) to outside the EEA, we may be required to take specific additional measures to safeguard the relevant personal information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In countries which have not had these approvals, we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.
Please contact us if you would like to see a copy of the specific safeguards applied to the export of your personal information.
Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain the information you provided to us as long as necessary to provide you with the services you requested through our Website and until the time limit for claims which may arise from those services has expired, or to comply with regulatory requirements regarding the retention of such data. So if we use your personal information for more than one purpose we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose(s) with a shorter period once that period expires.
When personal data is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.
Your rights & contacting us
You have the right to ask us not to process your personal information for marketing purposes. We will inform you if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by not checking certain boxes in the forms we use to collect your personal information. You can also exercise the right at any time by contacting us as set out in the “Contacting Us” section below.
We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by contacting us as set out in the “Contacting Us” section below.
If you have any questions in relation to our use of your personal information, you should first contact our Data Protection Officers. Under certain conditions, you may have the right to require us to
- Provide you with further details on the use we make of your information.
- Provide you with a copy of your personal information that we hold.
- Update any inaccuracies in the personal information we hold (please see paragraph 5.2).
- Delete any personal information that we no longer have a lawful ground to use.
- Where processing is based on consent, to withdraw your consent so that we stop that particular processing (see paragraph 5.1 for marketing).
- Object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights.
- Restrict how we use your information whilst a complaint is being investigated.
Please be aware that certain exceptions apply to the exercise of these rights and so you will not be able to exercise them in all situations. In addition, these will vary slightly between EU Member States. For instance, in France, in addition to the rights listed above, you also have the right to define directives as to how you wish your personal data to be used after your death. If you wish to exercise any of these rights we will check your entitlement and respond within the applicable timescale.
If you are not satisfied with our use of your personal information or our response to any exercise of these rights, you have the right to complain to the Supervisory Authority of your usual place of residence or place where the alleged breach to the law occurred.
If you have any questions in relation to this policy or want to exercise any of your subject rights described above, request, please contact our Data Protection Officer.
Please see here for a list of which group companies will be data controllers in which countries and obtain the contact details of the relevant Data Protection Officer.
Annex A: Use Justifications
Use of personal information under EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the grounds in respect of each use in this policy. We note the grounds we use to justify each use of your information next to the use in the “Uses of your personal information” section of this policy.
These are the principal legal grounds that justify our use of your information:
where you have consented to our use of your information (you will have been presented with a consent form in relation to any such use and may withdraw your consent by using the “unsubscribe” option in the email you have received or by using the Contact Us form).
Contract performance: where your information is necessary to enter into or perform our contract with you.
Legal obligation: where we need to use your information to comply with our legal obligations.
Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.