1.2 We are committed to safeguarding the privacy of our website visitors; in this policy, we explain how we endeavour to ensure that the information you submit to us remains private and that it is only used for purposes described within this policy.
2.1 This document is part of Daxtra Group set of Procedures and Policies.
3) Collecting Personal Information
3.1 We may collect, store, and use the following kinds of personal information:
(a) information about your computer and your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
(b) information that you provide to us when registering with our website (including but not limited to your email address, name, phone number, company name & company HQ).
(c) information that you provide when uploading your CV/resume on our website (including but not limited to your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details);
(d) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address and any information outlined in points (b) & (c) above.
(e) information that you provide to us when using the services on our website or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use).
(f) information contained in or relating to any communications that you send to us or send through our website (including the communication content and metadata associated with the communication);
(g) any other personal information that you choose to send to us.
3.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
4) Using Your Personal Information
4.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
4.2 We may use your personal information to:
(a) administer our website and business;
(b) personalise our website for you;
(c) enable your use of the services available on our website;
(d) send you goods purchased through our website;
(e) supply to you, services purchased through our website;
(f) send statements, invoices and payment reminders to you, and collect payments from you;
(g) send you non-marketing commercial communications;
(h) send you email notifications that you have specifically requested;
(i) send you our email newsletter, (you can inform us at any time if you no longer require the newsletter);
(j) send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(k) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
(l) deal with enquiries and complaints made by or about you relating to our website;
(m) keep our website secure and prevent fraud;
(n) verify compliance with the terms and conditions governing the use of our website.
4.3 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
5) Disclosing Personal Information
5.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
5.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
5.3 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
(e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
5.4 Except as provided in this policy, we will not provide your personal information to third parties.
6) International Data Transfers
6.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
6.2 Information that we collect may be transferred to countries which do not have data protection laws equivalent to those in force in the European Economic Area.
6.3 You expressly agree to the transfers of personal information described in this Section 6.
7) Retaining Personal Information
7.1 This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
7.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. Our data retention period is currently set to 36 months. We have ascertained that as this is a business-to-business enquiry we have a legitimate interest to hold your data for this period in order to keep you up to date on all our products and offerings. Your data is stored on 2-factor authentication secured CRM software, that also has physical security measures in place that have passed both ISO 9001 & ISO-27001 accreditation. Your data is stored for future contact by our sales/marketing team around the initial reason you contacted us, as well as for other related products that we feel appropriate.
7.3 Without prejudice to Section 7.2, we will usually delete personal data falling within the categories set out below at the date/time set out below:
(a) All personal data will be deleted upon request from you, the data subject. We define as this as a business-to-business relationship, that we have a legitimate interest to hold your data to keep in contact with you until you contact us to say otherwise or unsubscribe from our newsletter contact.
7.4 Notwithstanding the other provisions of this Section 7, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
8) Security of your Personal Information
8.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
8.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
8.3 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.4 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
9.1 We may update this policy from time to time by publishing a new version on our website.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
9.3 We may notify you of changes to this policy by email.
10) Your Rights
10.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) a reasonable fee payment to cover the administrative costs of complying with a request if it is manifestly unfounded or excessive, this may also be applied if an individual makes a request for further copies of their data.
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
10.2 We may withhold personal information that you request to the extent permitted by law.
10.3 You may instruct us at any time not to process your personal information for marketing purposes.
10.5 You can withdraw your consent for us to hold your details at any stage by emailing email@example.com, and we will provide you with options to opt out of being contacted on our marketing communications. You can also request your details to be deleted at any stage by the same process as well.
10.6 You have the right to lodge a complaint with your relevant supervisory authority.
11) Third Party Websites
11.1 Our website includes hyperlinks to, and details of, third party websites.
11.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
12) Updating Information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13.2 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 stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.3 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.
13.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
13.5 We may use both session and persistent cookies on our website.
13.6 Most browsers allow you to refuse to accept cookies; if you require help and support configuring the setup for this please contact firstname.lastname@example.org.
13.7 Blocking all cookies will have a negative impact upon the usability of many websites.
13.8 If you block cookies, you will not be able to use all the features on our website.
13.9 You can delete cookies already stored on your computer, if you require help and support configuring the setup for this please contact email@example.com.
13.10 Deleting cookies will have a negative impact on the usability of many websites.
14) Our Details
14.1 Daxtra’s Data Protection Officer is April Read and can be contacted by email at firstname.lastname@example.org.
14.2 Our websites www.daxtra.com, www.daxtra.cn, www.peoplebank.com, www.daxtra.co.jp, fr.daxtra.com and de.daxtra.com are owned and operated by Daxtra Group of Companies.
14.3 You can contact us by the following methods:
telephone: +44 131 653 1250 (Europe), +1 804 767 1351 (USA), +852 5803 6991 (Hong Kong), +61 2 8705 5445 (Sydney), + 81 50 6877 6405 (Tokyo), +86 21 8025 1557 (Shenzhen), + 65 3158 6790 (Singapore).