Most of the data we collect and hold about you is for the purpose of supplying you with our products and services. We also use data to help make our products and services better. By visiting our website, you are agreeing to our use of your personal information as described.
What information do we collect about you?
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 collect Information that you provide to us:
- Identity Data such as first name, last name and username or similar identifier.
- Contact Data such as company name, country, billing address, delivery address, email address and telephone numbers.
- Transaction Data such as details about payments to and from you and other details of products and services you have purchased from us.
- Profile Data includes your interests, preferences, feedback and survey responses.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
And we collect information from your interactions with us:
- Usage Data includes information about how you use our website, products and services.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as it does 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.
If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we would still treat the combined data as personal data which will be used in accordance with this Policy.
If you fail to provide personal data
If 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 goods or services). We will notify you at the time if that means we have to cancel a service we are providing you with.
- How we will collect your personal data
We will collect personal information about you in the following ways:
- Direct interactions. You may give us your Identity and Contact Data by submitting information online via our website, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- subscribe to one of our services or publications;
- create an account;
- request marketing to be sent to you;
- enter a survey; or
- give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register.
- Technical Data from analytics providers;
- advertising networks;
- search information providers;
- Contact and Transaction Data from providers of technical, payment and delivery services; and
- Identity and Contact Data from data brokers or aggregators.
How we will use your personal data
It’s important that you understand what we’ll do with the data that we hold about you, as well as the lawful reasons we are allowed to do this.
We use the information we hold about you for the following purposes:
- Performing our contract with you: We need to process information in order to supply the products and services you’ve asked for, for example setting up your XMOS account, fulfilling an order under our contract, checking license eligibility and collecting payment.
- For our legitimate business interests (or those of a third party): This means using your information that is necessary for us to build our business and provide our services to you. We consider and balance any potential impact on you and your rights before we access your personal data for our legitimate interests. Our legitimate interests include:
- Maintaining and improving our services: For example:
- understanding which parts of the website are easiest to use. We may also contact you for suggestions on how we can improve the way we provide our services to you.
- Providing personalised services including your XMOS account
- Communicating with you about our services for example with news, products updates and new products that we think you might be interested in.
- Help prevent and detect fraud and recover debt.
- Fulfilling our legal and regulatory obligations.
We may need to disclose information to law enforcement agencies where we are obliged to do so.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to 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.
If you have questions about the lawful basis on which we collect and use your information, you can email our Data Protection Manager at email@example.com
Promotional offers from us
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 products, services and offers may be relevant for you (“marketing”).
You will receive marketing communications from us if you have requested information from us or instructed us to provide services and you have not opted out of receiving that marketing. You can opt-out of receiving marketing messages from us by following the opt-out link provided in our messages or by emailing firstname.lastname@example.org.
We will get your express opt-in consent before we share your personal data with any company outside XMOS for marketing purposes.
Change of purpose
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.
Who do we share your information with?
We may have to share your personal data with the parties set out below for the reasons set out in this policy or as otherwise required by law. That includes the following types of organisations:
- Third parties for the purposes of fraud protection and credit risk reduction.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
XMOS does not sell, rent, or lease your personal information to third parties. 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.
Where do we transfer your information?
We may transfer your information to, or store it in, countries located outside the European Economic Area (‘EEA’) which do not have as developed data protection laws. It may also be processed by staff operating outside the EEA who work for us or one of our suppliers.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. Click here for more information.
- Where we use certain service providers outside the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection it would have in Europe. Click here for more information.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. Click here for more information.
By providing your information to us you agree and consent to us transferring to, and storing your information at, a destination outside the EEA. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
How do we keep your personal data secure?
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.
All your information is stored on our secure servers, or on the servers of our suppliers.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will apply our normal procedures and comply with legal requirements to protect your information, we cannot guarantee the security of your information transmitted to / from our website or on our behalf, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long will we keep your personal data for?
We keep the personal information for no longer than is necessary to fulfil the purposes for which we collected it. The length of time depends on the purposes for which we use it, or otherwise to meet our legal obligations.
We will delete any information as soon as we no longer have a valid reason to hold it. If this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible.
If we collect or handle your personal data, you have rights as an individual which you can exercise in relation to the information we hold about you:
- To correct or update your personal data, you can login to your XMOS account.
- To delete your personal data, you can email us at email@example.com. We will delete any information that we no longer need to hold but we won’t always be required to do this. If this is the case, we’ll explain why.
- To get access to all the personal information that we hold, you can email us as firstname.lastname@example.org with the subject line of ‘Subject Access Request’.
- To object to the processing of your personal information, you can email us at email@example.com. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- To opt-out of marketing communications you can click the opt-out link at the bottom of our communications or email us at firstname.lastname@example.org.
- To request restriction on processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- To request transfer of your personal data to you or to a third party, email us at email@example.com
- To withdraw consent where we are relying on consent to process your personal data, email us at firstname.lastname@example.org. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
If you’re unhappy with how we’ve handled or processed your personal information – or you want further information about your rights – you have the right to contact the Information Commissioner’s’ Office, the supervisory body that regulates handling of personal information in the UK.
You will ordinarily 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 may refuse to comply with your request in these circumstances.
You can get in touch about anything in this Policy by emailing our Data Protection Manager at email@example.com.
About this Policy
For the purposes of this Policy, “we”, “us”, “our” and “XMOS” means XMOS Limited, registered company number 05494985. Unless otherwise stated, XMOS is the controller and is responsible for your personal data.
This Policy applies to how we use your information in relation to our products and services generally. This Policy doesn’t apply to other companies’ sites that you get to through our website, so make sure you’ve read their policy before putting your personal information on their site.
Changes to the Policy and your duty to inform us of changes
Last updated on 30 August 2018.