Introduction
XBP Global Technologies as a Group of Companies (hereinafter referred to as ‘XBP Global’ or/and ‘We’) takes the privacy of an individual’s data very seriously and is committed to protecting and respecting individual’s privacy. The Data Controller of your personal data is XBP Global Technologies B.V., Herengracht 576b, 1017 CJ AMSTERDAM – Netherlands –Organisation no :72638974 in conjunction with a Joint Controller of XBP Global Technologies BPA, LLC., 2701 East Grauwyler Road Irving, TX 75061 United States of America – Organisation no: 471347291. In the United Kingdom, Data Controllers appointed its representative – XBP Global Technologies Ltd, Baronsmeded, The Avenue, Egham, England, TW20 9AB Organisation No.: 01283512.
This Privacy Notice describes how we collect, use and process your personal data through our website, with whom we might share it and how long we usually keep it. This also makes you aware of your rights under the European Economic Area or the United Kingdom data protection legislations. This Privacy Notice applies to the personal data of visitors, registered users and subscribers of DMR product and related websites.
Definitions
Visitor refers to a user who accesses the DMR sites but does not register;
Registered User refers to a user who signs up for an account with the DMR;
Subscriber refers to a Registered User who purchases a subscription plan for the DMR;
DMR refers to Digital Mailrooom product created and is a brand owned by XBP Global.
What information do we collect ?
We collect, store and use some or all of the below listed personal data:
I. Visitor
II. Registered User
III. Subscriber
We won’t collect, store and use any of the ‘special categories’ of personal information. We do not intentionally collect information from children under the age of 16. Any linked websites of XBP Global will have their own privacy notices, and different rules of collecting and processing personal data.
How do we collect this data?
We collect information directly from you when you visit our website or by filling in online forms or by corresponding with us by post, phone, email, social media or otherwise. It also concerns situations when you decide to sign up for marketing communications to be sent to you.
If you fail to provide certain information when requested, we may not be able to comply with contractual obligations and perform the contract we have entered into with you (such as replying on your request), or we may be prevented from complying with our legal obligations.
When you interact with our website, we may automatically collect Technical Data and/or Usage Data, unless you have opted-out or have otherwise refused to provide consent. Following data may be used:
In addition, We may receive personal data from third parties which shared with us your data as described situation when you authenticate yourself using Google account. Furthermore, Technical Data from analytics and email subscription providers such as LinkedIn, Pardot, Google Analytics or Facebook can be shared with us too. If we receive such data from our third party providers and We will be considered as Data Controller, each time we will inform you from which source the personal data originates, and provide details in separate privacy notice.
We might aggregate data from different sources (both internally and externally) to have a better understanding of your preference and interests, and be able to provide you more relevant communications.
How do we use personal information?
We may process personal information for the following reasons:
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 we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which we are using that allows us to do so. When required, we will ask your consent before starting among other marketing activities. Please note that even if you opt out from receiving marketing communications, you might still receive administrative, service or other important notices.
What legal basis do we have for processing your personal data?
As a rule our legal basis for the processing of personal data are:
This legal basis have been defined in the GDPR. We describe each of these below.
Consent
Should we want or need to rely on consent to lawfully process your data, we will request your written consent for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time (as set out below).
You have the right to withdraw your consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
Performance of a contract
We will rely on performance of a contract to provide you the services and manage relationships.
Legal Obligation
We will rely on legal obligation, if we are legally required to hold information on you to fulfil our legal obligations – including where you are placed in a role in a regulated environment. This would include the requirement to obtain and hold data regarding criminal convictions.
This also concerns if XBP Global would like to establish or defend it’s legal claims:
Our Legitimate Business Interests
Our legitimate business interest means processing of personal data is necessary to enable XBP Global to conduct its business e.g. matters related to the protection of property, employees and matters related to providing security to persons present at premises. We never override fundamental rights and freedoms of our employees which require protection of personal data.
Local Legislations and Regulations
In certain cases, employment, financial (i.e. anti-money laundering) and other local legislation may require that we collect information that is considered to be ‘delicate’. In these circumstances we will ensure that only the minimum required is collected, and that it is securely stored and that it is deleted when no longer required.
Below you can find examples of legal basis per type of processing which we may undertake:
| Type of processing | Legal basis |
|---|---|
| Maintain an account and/or provide customer service; | Performance of a contract |
| Communicate with you about products, services, offers, promotions, rewards and events offered by us (marketing activity) | Consent |
| Give an option to accept or reject cookies on our website | Legal obligation |
| Monitor and analyze trends on our website | Legitimate interest |
When do we share personal data?
XBP Global being an international company processes data in locations both in the EEA or the UK and outside the EEA or the UK. We share your personal information with other entities of XBP Global as part of our regular reporting activities on company performance, in the context of a business reorganization or restructuring exercise, for system maintenance support and hosting of data. Several support services such as finance are centralized and located outside of the EEA or the UK. We transfer the personal information we collect about you to XBP Global entities within EEA, UK and in USA and India.
We may share your personal information with
Where we do share your data with 3rd parties or other XBP Global entities, the shared data will be limited to that which is required by the 3rd party or other XBP Global entity to provide the required processing. In such cases your personal data are safeguarded by Data Processing Agreements, committing outsourced service providers to process your personal data for specified purposes and in accordance with our instructions, comply with the GDPR and/or the UK-GDPR and apply appropriate security measures to protect your personal information in line with our policies. All transfers outside EEA made to countries which are considered by the European Commission, or by UK government relating to the transfers outside UK, to not provide an adequate level of protection of personal information are safeguarded with agreements based on Standard Contractual Clauses approved by European Commission, and/or UK government realting to the transfers outside UK. Where data is being transferred to USA, we have established appropriate impact assessments to verify whether importers of data located in USA conform European data protection legislation.
As an example we have listed on table below several categories of personal data which We may share with other entities of XBP Global and selected third parties:
| Third Party | Categories of personal data shared | Comments |
|---|---|---|
| XBP Global India | internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website. | Acts as a Data Processor – Website updating and technical deployments. |
More details about sharing data can be obtained from contact point specified in point 12.
How do we secure personal data?
Once We have received your information, we will use strict procedures and security features to prevent unauthorised access. All information you provide to us is stored securely on our servers. We have in place the following measure to ensure that confidentiality, integrity and availability of the personal data we hold on you.
We are avoiding personal data collection and usage in paper format. If required, the paper documents and copies will be always stored in locked-up premises with very restricted access to the limited members of staff in line with our internal policy.
How long do we keep your personal data for?
We understand our legal duty to retain accurate data, that’s why we will only retain your personal data as long as we have consent from you.
Regardless of the above, every 2 years we will send you a communication where we will ask you to re-authorise your consent for marketing communications, if you signed up.
If you are Registered user or Subscriber, you personal data will be stored as long as you maintain an account and use our service.
If you consent to receiving our Newsletter, you revoke consent at any time by clicking the ‘unsubscribe’ button on our Newsletter communication or by contacting us at any time. All paper records will be deleted by secure shredding of the paper files electronic copies will be deleted by secure erasure in accordance with applicable laws and regulations.
Details about retention schedule can be obtained from contact point specified in point 12.
Your rights in relation to personal data
Under the GDPR you have the right to:
If you wish to exercise any of the rights set out above, please contact thel contact with details of what information is to be provided.
Use of automated decision-making and profiling
We don’t undertake automated decision making, however we use profiling through our CRM systems. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process.
Changes to our Privacy Notice
If any changes we would make to our Privacy Notice in the future, we will inform you by placing the appropriate information on our website.
How to contact us?
Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to:
XBP Global TECHNOLOGIES Phone number: 1-844-XELATEC, EEA address: Herengracht 576b, 1017 CJ AMSTERDAM, The Netherlands UK address: XBP Global Technologies Ltd, Baronsmeded, The Avenue, Egham, England, TW20 9AB Email: emeamarketing@exelatech.com |
You have the right to make a complaint at any time to the Local Supervisory Authority We would however, appreciate the chance to deal with your concerns before you approach the Local Supervisory Authority so we encourage you to contact us in the first instance:
XBP Global Lead Supervisory Authority in the EEA: Autoriteit Persoonsgegevens Bezuidenhoutseweg 30 2594 AV DEN HAAG +31 (0) 70-8888 500 XBP Global Lead Supervisory Authority in the UK: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF |
How do we use cookies ?
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. 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.
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. We use both session and persistent cookies on our website.