ExpatUX Ltd (“We”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
What information do we collect?
The following tables set out what personal information we may process, why we process that personal information and the legal basis for such processing:
1.1 Information you give us.
|What personal data might be supplied to us?||Why we process that personal data:||The legal basis for processing that personal data.|
|Communication Data: If you communicate with us (through our website contact form, via email, phone, post or any other means of communication by which you choose to contact us), we will process the information contained in your communication. This information may include your name and contact information, the content of your communication and any metadata our website generates where you communicate with us using the contact form available on our website.||We will process that information so we can correspond with you and keep records of such correspondence.||The legal basis we rely on for processing this data is as follows:- Our legitimate interests; or- Consent.|
1.2 Information we collect from other sources.
|What personal data might we collect from other sources?||Why we process such personal data:||The legal basis for processing this personal data.|
|Technical Data: Technical information relating to your use of our websites, including (1) the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. We may obtain this data through our analytics tracking system; and (2) information about your visit to our website(s), including the full Uniform Resource Locators (URL), clickstream to, through and from our website(s) (including date and time), products and services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.||We process this data so we can monitor and analyse how our websites are used so we can improve our websites and our services. This helps us to administer our business and improve the services we offer.||The legal basis we rely on for processing this data is as follows:- Our legitimate interests.|
- When will we disclose your personal data to others?
3.1 We may need to share your personal information with certain selected third parties including:
(a) our business partners, suppliers and sub-contractors for the purpose of performing any contract we have with you or them. In particular, we use third party companies to process your personal data in order: (1) to carry out our identity and credit verification checks, to provide: (2) confidential information destruction and deletion services; (3) data storage services; (4) communication facilities; (5) document production services; (6) event support and management services; (7) public relations services; (8) banking services;; (9) conferencing facilities and call answering facilities; and (10) any other services which we deem are necessary to properly manage our business and comply with our legal and regulatory obligations.
(b) analytics and search engine providers that assist us in the improvement and optimisation of our website.
3.2 We will also disclose your personal information to third parties in the following circumstances:
(a) If we sell or buy any business or assets, in which case we may need to disclose certain personal data to the prospective seller or buyer of such business or assets.
(b) If all or most of our assets are acquired by a third party, in which case personal data held by us about our clients will be one of the transferred assets.
(c) If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce any legal agreement we have with you; or to protect our rights or property, or the safety of us, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- Where do we store your personal data?
We will always try to ensure that your personal data is processed within the European Economic Area. In some circumstances this will not be possible. In circumstances where it is necessary for us to transfer your personal data outside the European Economic Area, we will only transfer such personal data to third parties where we have carried out due diligence on such third parties to ensure they will protect your personal data using similar standards and safeguards as we have. We will also have contractual provisions in place with such third parties to ensure your personal data is protected. Such contractual provisions will be based on the standard contractual clauses approved by the European Commission for the transfer of data outside the EEA or such other appropriate standards as are required from time to time by the European Commission or the UK Government. You consent to the transfer of your personal data outside of the EEA, as long as we comply with these requirements.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not always secure. Although we will do our best to protect your personal data, and we will maintain appropriate technical and organisation measures to protect your personal data, we cannot guarantee the security of your data transmitted to our website; 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.
- Storage and deletion of personal data
(a) Any personal data that we process will be deleted from our systems once we have completed the purpose for which we were processing the personal data. In some cases, the purpose for which we are processing your personal data will last for a considerable period (for example, if you are a long term client of ours, we will need to store your data until our relationship with you comes to an end).
(b) We will determine the period for which we need to retain your data, acting reasonably, and taking into consideration a number of factors such as your relationship with us, your engagement with us, and the fulfilment of contracts we have with you.
(c) We may need to retain your personal data where this is necessary to comply with our legal or regulatory obligations, or to protect the vital interest or the vital interests of another natural person.
- Data security
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.
- Your rights
7.1 Under data protection laws you have the following fundamental rights:
(a) The right to access the personal data we hold about you;
(b) The right to have your personal data corrected if there are errors or inaccuracies in it, or your personal data is incomplete;
(c) The right to restrict the processing we carry out in relation to your personal data;
(d) The right to object to the processing we carry out in relation to your personal data;
(e) The right to have the personal data we hold about you provided to you in a useable format;
(f) The right to complain to a supervisory authority (in the UK this is the Information Commissioner’s Office) about how and/or why we are processing your personal data;
(g) The right to tell us you no longer consent to us processing your personal data. In practice you will usually agree in advance to us using your personal data for marketing purposes and if you no longer wish us to use your personal data for marketing purposes, you can opt out of receiving such marketing messages at any time. You can do this by unsubscribing from the marketing messages we send you, notifying us in writing.
7.2 You can ask us to provide you with details of any personal data we hold about you. You do not have to pay us a fee to access your personal data unless we believe your access request is unfounded, repetitive or excessive. In this case we may charge you a reasonable fee to access your personal data or we may decide not to comply with your request. We will notify you if this is the case. We will require you to provide appropriate evidence of your identity before we respond to your request. Typically this identification evidence will be a photocopy of your passport or photo driving licence, which a solicitor or bank has certified as being a true copy of the original and a copy of a recent utility bill detailing your current address.
7.3 Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
7.4 If you think that any of the data we hold about you is incorrect or inaccurate, you can contact us to correct such data.
- Information about us
- Any questions?
Data Protection Officer
21 Verley Close