This policy is provided in a layered format so that you can click on the header of each section to expand it.
The Xoomworks group of companies is made up of the following different legal entities:
Xoomworks Ltd, a limited company registered in England (company number: 3948354), whose registered office is Dunstan House, 14a St Cross Street, London, EC1N 8XA, United Kingdom.
Xoomworks Bulgaria EOOD, a limited company registered in Bulgaria (company number: 203375370), whose registered office is Sofia 1000, 2a Saborna Street, 4th Floor.
Xoomworks France SARL, a limited company registered in France (company number: 424950459), whose registered office is 38 Rue des Mathurins, Paris, 75008.
Xoomworks Development RO SRL, a limited company registered in Romania (company number: J12/4865/09.11.2007), whose registered office is Victor Babes Nr. 29, Cluj-Napoca.
Xoomworks Ltd is the controller in respect of your personal data collected through our digital services.
Our full contact information can be found here
Personal data or personal information is any information about you from which you can be identified. It does not include data where your identity has been removed (this is called anonymous data.
We collect and process different kinds of personal information about you and use different methods to collect it, as follows:
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 this data does not directly or indirectly reveal your identity.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences or any data relating to children.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by sending an email to firstname.lastname@example.org.
We will only use your personal data when the law allows us to. Most commonly we will use your personal data where it is necessary for our legitimate interests. Our legitimate business interest is in conducting and managing our business to enable us to give you the best services, and to provide you with the best and most secure experience when using our digital services. We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
We use your personal information in connection with our business activities. In particular, we may use your personal information in the following ways:
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 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 and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if we have your personal information and you have not opted out of receiving them. You can indicate the specific types of marketing communications you are particularly interested in receiving from us, and we will tailor the communications you receive to reflect your choices. We may however also send you other communications that we think may be of interest to you, unless you opt out of receiving them.
You can change your preferences or ask us to stop contacting you with marketing information by any communication channel (telephone, email, post or SMS) at any time by following the opt-out links on any marketing message sent to you, or by emailing us at email@example.com. Please note that, even if you choose not to receive marketing information, we may still use your personal information to provide you with important services communications.
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 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.
We may share your personal information with the following 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.
Many of the companies and other persons with whom we share your personal information are based outside of the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. [This does not apply to our group of companies who are all based within the EEA.]
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is given to it by ensuring at least one of the following safeguards is implemented:
We have set out detailed information about the way in which we ensure that your information is safe when we transfer it outside of the EEA in our Information Security Information System (ISMS) which has been developed in line with ISO 27001:2013 and our Information Security Policy. Please email us at firstname.lastname@example.org if you would like to see these documents or would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Cookies are small text files that we transfer to your computer's hard drive to enable our systems to recognize your browser and help us to track visitors to our digital services so we can better understand what portions of our digital services best serve you.
To find out more about the types of cookies we use on our digital services, how we use them and how you can change your cookies settings, please read our Cookies policy, available at https://www.xoomworks.com/cookies-privacy-policy/.
Please note that such third-party websites and applications are not under our control. When you click through to these websites or access these applications you leave the area controlled by us and you allow third parties to collect or share data about you. We are not responsible for the privacy statements of any third party websites, and do not accept responsibility for any issues arising in connection with that third party's use of your personal data.
Our security procedures mean that we may occasionally request proof of identity before we are able to disclose sensitive information to you.
The transmission of information via the internet is not completely secure; this risk is common across the internet and not specific to our Digital Services. We do everything we can to ensure the security, integrity and confidentiality of your information.
It is important for you to protect against unauthorised access to your password and to your computing device. Be sure to sign off and close your browser when you have finished your user session. This will help to ensure that others do not access your personal information if you share your computing device or use a computing device in a public place such as a library or internet café.
We only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the risk of harm from it being used or disclosed without our authority, the purposes for which we process it and whether we can achieve those purposes without it. We also take into account the applicable legal requirements.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of these rights, please contact us here.
You will 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.
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.
You have the right to:
If you have a complaint or a concern about Xoomworks’ information rights practices, you can report it to the Information Commissioner’s Office (ICO) at https://ico.org.uk/concerns/.
You may change your marketing preferences or update your personal information at any time by writing to Xoomworks Customer Services, Dunstan House, 14a St Cross Street, London, EC1N 8XA, United Kingdom, online via https://www.xoomworks.com/contact-us/ or by emailing email@example.com. Should you wish to unsubscribe entirely from marketing communications, then please email firstname.lastname@example.org. We will process any requests of this nature as quickly as possible.
This Policy was last updated on 15 May 2018
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