ICX4 Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared. We respect and value the privacy all data subjects whose data we control and process, including everyone who visits our website, www.icx4.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
- Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of Our Site;|
|“Cookie”||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
|“personal data”||means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and|
|“We/Us/Our”||Means ICX4 Ltd, a limited company registered in England under company number 08456162, whose registered office is at 1A The Moorings, Dane Road Industrial Estate, Sale, Cheshire M33 7BH, UK, and whose main trading address is 114-116 Curtain Road, London EC2A 3AH, UK.|
- Information About Us
- Our Site is owned and operated by Us.
- Our Data Protection Officer is a member of our Data Protection Committee and can be contacted by email at firstname.lastname@example.org, by telephone on +44 20 3872 6920, or by post to our London Address as per our Contact Us page.
- We are a registered with the Information Commissioner’s Office, registration ID ZA067430.
- What Does This Policy Cover?
- Your Rights
- As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you (see section 12);
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
- If you have any cause for complaint about Our use of your personal data, please contact Us and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
- For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
- As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- What Data Do We Collect?
- date of birth;
- business/company name;
- job title;
- professional history;
- salary expectations;
- financial information;
- health information;
- legal status such as nationality, working rights, criminal history;
- ID documentation or reference numbers such as passport number, drivers licence number, NI number;
- contact information such as email addresses, physical addresses, telephone numbers, social media;
- opinions or questions freely given on comments or question sections;
- demographic information such as post code, preferences, and interests;
- IP address;
- web browser type and version;
- operating system;
- a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
- How Do We Use Your Data?
- All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Act 1998 and GDPR at all times. For more details on security see section 7, below.
- Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, that you have consented to Our use of your personal data (e.g. by subscribing to receive marketing emails), because it is in Our legitimate interests, in the public interest or your own vital interests, or because the law requires it. Specifically, We may use your data for the following purposes:
- Providing you with and/or receiving from you: goods, services, and/or employment as contracted;
- Entering into discussions to establish a contract for the exchange of goods, services and/or employment;
- Providing you with information as requested;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Replying to emails from you;
- Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking on the ‘Unsubscribe’ button on such emails, or directly requesting removal of your personal data to email@example.com;
- Market research;
- Analysing your use of Our Site to enable Us to continually improve Our Site and your user experience;
- With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and/or post with information, news and offers on Your Job Application and/or Our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 1998, GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
- You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it. You can change your Cookie Consent status here: http://icx4.com/cookie-policy/, can opt out of our marketing emails on all marketing emails sent on or after 25th May 2018 or by making a request in writing to firstname.lastname@example.org.
- We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- As per the retention period specified in Our contract with you;
- As required by law or regulation;
- All data used in accounts payable and receivable, payroll, personnel files, expired contracts and all email correspondence is kept for up to seven (7) years or until a data removal request has been actioned;
- For as long as contractual discussions prevail, remain relevant or until a data removal request has been actioned;
- The Cookie Cache for Our Site is cleared annually;
- Comments submitted to Blog Posts (and related information) on Our Site are kept as long as the post is considered relevant to Our Site. Data Subjects can request the removal of their comment and related personal data by submitting a written request to email@example.com.
- Job application information is kept for one year as a standard. Some applicants may be contacted via email to inform them that We are keeping their application on file for future openings and have the option to opt out of this anytime. Job applicants may request their data is removed from our system by submitting a written request to firstname.lastname@example.org.
- All new marketing contacts are added with consent to our mailing list, where consent can be revoked at any time by the Data Subject; either by clicking the ‘Unsubscribe’ button on our email communications or by submitting a written request to email@example.com.
- How and Where Do We Store Your Data?
- We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
- Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by continuing your relationship with Us, providing consent to Us, using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998 and GDPR including:
- Confirmation of GDPR compliance from all third party processors engaged directly by US.
- Privacy Impact Assessments carried out where required for third party processors.
- Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure personal data.
- Steps We take to secure and protect your data include:
- All internal systems are secured as per the IT Security Policy, available on request to firstname.lastname@example.org;
- Marketing website secure hosting via GoDaddy;
- Marketing website security features provided by WordPress;
- All job applicant details are stored within the BambooHR System, on UK servers, a third party processor whom has provided written confirmation of their GDPR compliance;
- All communications with marketing lists are conducted through Microsoft Office365 or MailChimp, third party processors which have provided written confirmation of their GDPR compliance.
- Do We Share Your Data?
- In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
- We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
- We may compile statistics about the use of Our Site and including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
- We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998 and GDPR. Currently we have Data Processing Agreements with third party processors in Japan & India, under such agreements these processors have an obligation to meet equivalent data protection standards as would be provided in the UK and EU.
- What Happens If Our Business Changes Hands?
- In the event that any of your data is to be transferred in such a manner, all efforts will be made to contact you in advance and inform you of the changes. When contacted you may be given the choice to have your data deleted or withheld from the new owner or controller.
- How Can You Control Your Data?
- When you submit personal data to Us and/or via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by making a request to email@example.com).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- Your Right to Withhold Information
- You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
- You may request to restrict the processing of personal data routinely collected for the purpose of establishing and fulfilling a contract; where it is possible to fulfil the contract without such information, and where permitted by law, We will comply to written requests to withhold, delete or limit the processing of your personal data.
- How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge, unless responding to it is likely to be complex and will involve looking extensively at a high volume of data, in which case you will be notified of the relevant fee involved. Please contact Us for more details at firstname.lastname@example.org.