Privacy Policy

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 Xoomworks Ltd c/o Work.Life, 33 Foley Street, London, W1W 7TL, 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.

This privacy policy is issued on behalf of all the Xoomworks group of companies described above, so when we mention “Xoomworks”, “we”, “us” or “our” in this privacy policy we are referring to the relevant company in the Xoomworks group responsible for processing your personal information. We will let you know which entity will be the data controller for your personal data when you purchase a product or service with us or otherwise interact with us (including through our digital services).

When we refer to “digital services” in this privacy policy, we are referring to our websites at the following URLs: xoomworks.com, xoomworks.com/procurement, xoomworks.com/technology, xoomworks.com/bi, technology.how and any other software, information and web-based applications that we make available for your use, at any time.

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:

• Identity and contact information: this includes your full name, contact details, (including your email address and mobile phone number), job title, physical address and information about the company you work for.
• Financial and transactional data: this includes bank account and payment card details, details about payments to and from you and other details of services you have purchased from us. We obtain this information through our direct interactions with you (either in person, on the phone, by email, by post or when you give this information via our digital services, and indirectly when it is provided to us by our providers of technical and payment services.
• Technical and usage data: if you use our digital services we collect certain information through automated technologies. The type of information we collect includes details of the device you use, traffic data, location data (including the country and telephone area code where your computer device is located, and other technology on the devices you use to access it, as well as information about how you use our digital services and the resources that you access (including the pages of our digital services that you view). We collect this personal data by using cookies, server logs and other similar technologies.
• Marketing and communications data: this includes your preferences in receiving marketing from us and your communication preferences.

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 privacy@xoomworks.com

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).

General
We use your personal information in connection with our business activities. In particular, we may use your personal information in the following ways:

• to carry out our obligations arising from any contracts entered into between you and us. For example, we will use your personal data to process and fulfil your requests for services. This may include using your personal data (e.g. your payment card details) to manage payments, and collect sums due to us;
• to manage and administer our relationship with you (including registering you as a new customer, contacting you regarding your orders and any services you have requested, responding to queries you submit to us, and notifying you of changes to our terms, our services or our privacy policy);
• to provide, enhance and personalise your experience when using our digital services;
• to identify and prevent fraud and to assess creditworthiness;
• to carry out market research. For example, we may contact you (including by email) to obtain your feedback on our products and services, and we may use details of your purchases to understand market trends and to identify popular products;
• to help us review, develop and improve the products and services we offer, including our digital services, and to improve and develop our customer database;
• for internal business and data analysis;
• to ascertain the products and services that are likely to be of particular interest to you in order to send tailored marketing information to you. For instance, if you browse pages of our procurement services in relation to a particular category, we may use this information to send you marketing communications about that category of product; and
• to administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance and support, reporting and hosting of data);
• in order to enforce or apply any contract we have with you (or which concerns you) such as our Digital Services T&Cs, Terms and Conditions of Sale, and Supply & Install Terms, and to protect our rights, property or safety or those of our customers, employees or other third parties; and
• to comply with any legal or regulatory obligation which is imposed on us.
  
  

Marketing
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 privacy@xoomworks.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:

other members of our group of companies. They may act as controllers or processors. For more information on our group of companies, including the countries in which they are based, please click here.

companies and other persons who provide services to us. For example, we engage other companies to update our databases of customer details (including the removal of repetitive information), analyse data, help us develop, provide and improve our digital services and provide us with marketing assistance. We also use IT subcontractors, hosting services and payroll providers (relevant to employee data only).

• professional advisers (including lawyers, bankers, auditors and insurers in the UK and overseas, who provide us with consultancy, banking, legal, insurance and accounting services);
• government bodies, regulators and other authorities in the UK and overseas, who require reporting of activities in certain circumstances (for example, HMRC, Office for National Statistics etc.);
• other parties as we may be required to by law or regulation, including for the purpose of detecting and preventing fraud and criminal activity, or pursuant to a court order; and
• 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 privacy policy.

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 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

where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and

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 Europe and the US.

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 privacy@xoomworks.com 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 recognise 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 here.

We may from time to time establish links to the websites of other members of our group (see here for list) from our digital services. Your use of those websites is subject to the terms of use and policies (including privacy policies) available on those websites.

From time to time we may also establish relationships with third parties that will enable you to access the websites or applications (such as video players) of such third parties directly from our digital services. Each third party operates its own privacy policy regarding the processing of personal information and the use of cookies on its website(s) or through its applications and you are advised to read the third party's privacy policy and cookies 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:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
• Request restriction of processing of 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;
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. 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.

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, Xoomworks Ltd c/o Work.Life, 33 Foley Street, London, W1W 7TL, United Kingdom online via our contact us page or by emailing privacy@xoomworks.com. Should you wish to unsubscribe entirely from marketing communications, then please email unsubscribe@xoomworks.com. We will process any requests of this nature as quickly as possible.

If you have any questions regarding this Privacy Policy, please feel free to contact us in any of the following ways:

• online via our contact us page
• by email at privacy@xoomworks.com, gdpr@xoomworks.com or legal@xoomworks.com.
• by writing to us at: Xoomworks Ltd c/o Work.Life, 33 Foley Street, London, W1W 7TL United Kingdom.

If we decide to change this Privacy Policy, we will post the updated Privacy Policy on our digital services, so that you are always aware of what personal information we collect, how we use it and under what circumstances we disclose it. The updated Privacy Policy will take effect as soon as it is posted. You can obtain historic versions of our Privacy Policy by contacting us here.