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At SXC Global and we are 100% committed to protecting the privacy and security of our customers and site visitors. We totally appreciate and respect how important privacy is. If you have any questions about how we Protect Your Privacy, send us an email at email@example.com.
This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.
The personal data that we collect
In this Section 2 we have set out the general categories of personal data that we process.
We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.
We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.
We may process information relating to our customer relationships ("customer relationship data"). The customer relationship data may include your name, the name of your business, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you. The source of the customer relationship data is you.
We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
Purposes of processing and legal bases
In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
Publications - We may process account data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is consent.
Relationships and communications - We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
Personalisation - We may process account data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is consent to offer the best possible experience for our website visitors and service users.
Direct marketing - We may process contact data, account data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent.
Research and analysis - We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is consent.
Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
Retaining and deleting personal data
This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
contact data will be retained for a minimum period of 12 months following the date of the most recent contact between you and us, and for a maximum period of 24 months;
account data will be retained for a minimum period of 6 months following the date of closure of the relevant account, and for a maximum period of 12 months following that date;
customer relationship data will be retained for a minimum period of 12 months following the date of termination of the relevant customer relationship and for a maximum period of 24 months following that date;
transaction data will be retained for a minimum period of 3 months following the date of the transaction, and for a maximum period of 6 months following that date;
communication data will be retained for a minimum period of 12 months following the date of the communication in question, and for a maximum period of 24 months following that date;
In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained.
Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Security of personal data
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
The following personal data will be stored by us in encrypted form: your name, date of birth, contact information and password(s).
Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
In this Section 6, we have listed the rights that you have under data protection law.
Your principal rights under data protection law are:
the right to access - you can ask for copies of your personal data;
the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
the right to erasure - you can ask us to erase your personal data;
the right to restrict processing - you can ask us to restrict the processing of your personal data;
the right to object to processing - you can object to the processing of your personal data;
the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
Third party websites
Our website includes hyperlinks to, and details of, third party websites.
In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
Personal data of children
Our website and products are targeted at persons over the age of 13.
If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
Please let us know if the personal information that we hold about you needs to be corrected or updated.
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 may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
Cookies used by our service providers
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
Blocking all cookies will have a negative impact upon the usability of many websites.
If you block cookies, you will not be able to use all the features on our website.
We may change this page from time to time, to reflect how we are processing your data. If we make significant changes, we will make that clear on the SXC Global website or by some other means of contact such as email, so that you are able to review the changes before you continue to use SXC Global.
Data protection officer
If you want to exercise your rights, have a complaint, or just have questions, please contact us at firstname.lastname@example.org.