Purpose of this Policy

Welcome to IXICO’s Privacy Policy. 

Protecting your privacy is important to IXICO. This privacy policy will inform you of your privacy rights, how we look after your personal data when you visit our website (regardless of where you visit it from) and how the law protects you.

Before you provide us with any Personal Data or browse our website, you should read through this privacy policy in full and make sure that you are comfortable with our privacy practices. 

Controller

This privacy policy is issued on behalf of the IXICO Group so when we mention IXICO, "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the IXICO Group responsible for processing your data. For the purposes of applicable data protection and privacy laws, IXICO plc ("IXICO", "us", "we"), with its registered offices at 4th Floor, Griffin Court, 15 Long Lane, London EC1A 9PN, is considered the “Data Controller” in respect of the Personal Data that it collects, uses and manages in accordance with this Privacy Policy (“Policy”).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below. 

Contact details

If you have any questions about this Policy or our privacy practices, you can contact us any time in writing at:

Postal Address:

IXICO Technologies Limited
FAO: Data Protection Officer
4th Floor Griffin Court
15 Long Lane
London EC1A 9PN
United Kingdom

Or by email to:
DPO@ixico.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

EU Representative

Individuals and data protection supervisory authorities in the EU may contact our data protection representative according to Article 27 GDPR:

DP-Dock GmbH, Attn: IXICO

Ballindamm 39, 20095 Hamburg, Germany

www.dp-dock.com

ixico@gdpr-rep.com

Changes to the privacy policy and your duty to inform us of changes

We reserve the right to modify or amend this Policy at any time by posting the revised Policy on our website. It is your responsibility to review the Policy from time to time. 

This version was last updated in January 2023.  

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The Personal Data We Collect About You

• Contact Data includes name, company/organisation details, email address and telephone numbers.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Our use of cookies and other similar technologies to process personal data is explained in our cookie policy which you can read at https://ixico.com/cookie-policy/.

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.

The purposes for which we process your Personal Data

We process your Personal Data for the following purposes:

• to provide you with information regarding our products and services;
• to provide you with information and communications such as newsletters and webinars which are of interest to you;
• to notify you of any changes to our products and services and to provide you with information in relation to similar goods and services that may be of interest;
• to administer our website and help improve our products and services;

• to use data analytics in relation to the use of our website, our products and services, our marketing and our customer or prospective customer data collection;
• to comply with applicable laws and regulations; and
• other business-related purposes, including negotiating, concluding and performing contracts, managing accounts and records, supporting corporate social responsibility activities, legal, regulatory and internal investigations and debt administration.

The legal basis for IXICO processing your Personal Data

In order to comply with applicable data privacy laws, IXICO is required to set out the legal basis for the processing of your Personal Data. In accordance with the purposes for which we collect and use your Personal Data as set out above, the legal basis for IXICO processing your Personal Data will typically be one of the following: 

• your consent;
• the performance of a contract that we have in place with you or other individuals;
• IXICO or our third parties’ legitimate business interests; or 
• compliance with our legal obligations.

Disclosure of your Personal Data

IXICO may share your Personal Data with people within IXICO who have a “need to know” that data for business or legal reasons, for example, in order to carry out an administrative function such as processing an invoice, or to direct a query that you have submitted to the relevant department within IXICO. We may also share the Personal Data you submit to us with any entity within the IXICO group worldwide.  We may disclose your Personal Data to third parties in the event that we sell, buy or merge any business or assets, including to the prospective seller or buyer of such business or assets. These entities are required to maintain the confidentiality of your data and are restricted from using it for any purpose other than the purposes set out in this Policy. 

We may also disclose your Personal Data to third parties including:

• Service providers acting as processors who provide IT, sales and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and authorities who require reporting of processing activities in certain circumstances. 

In relation to Personal Data obtained via our website, we may also disclose your Personal Data to analytics and search engine providers that assist us in the improvement and optimisation of our website, subject to the cookie section of this Policy. We may also decide to allow users to share comments, postings, testimonials, or other information. If you choose to submit such information to us, the information that you submit may be available generally to the public. Information that you provide in these areas may be read, collected, and used by others who access them. 

Transfers of Personal Data

Please note that any person to whom IXICO may disclose your Personal Data under this Policy may be situated in a country other than your own and that such country may provide a lower level of data protection requirements than your own country. By agreeing to this Policy, you consent to the transfer of your Personal Data to a country other than your own.

Whenever we transfer Personal Data across borders, we take legally required steps to ensure that adequate safeguards are in place to protect your Personal Data and to make sure it is treated in accordance with this Policy. 

Security

IXICO takes all reasonable technical and organisational security measures to protect Personal Data from accidental or unlawful destruction, accidental loss and unauthorised access, destruction, misuse, modification or disclosure.

Records retention

Your Personal Data is not kept for longer than is necessary for the purposes for which it is collected. This means that data and records (including Personal Data) are destroyed or erased from our systems when no longer required. The amount of time that records are kept for varies depending upon the type of Personal Data they contain.

Your rights

Applicable data privacy laws give rights to individuals in respect of Personal Data that organisations hold about them.  If you wish to:

• request a copy of the Personal Data that we hold about you; or
• request that we rectify, transfer, delete or object to or restrict the processing of your Personal Data,

please submit your written request to DPO@ixico.com.

You have the right to ask us not to process your Personal Data for marketing purposes. If you decide that you do not want to receive commercial communications from us, whether by email, telephone or post, you can “opt-out” from receiving such communications by clicking on the “unsubscribe” link provided at the bottom of each commercial email and updating your preferences, or by contacting us at DPO@ixico.com.  

Where you have consented to us using your Personal Data, you can withdraw that consent at any time.

If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it.

If you have an objection about how we have handled your Personal Data, you may be able to ask us to restrict how we use your Personal Data while your complaint is resolved. In some circumstances you can ask us to erase your Personal Data (a) by withdrawing your consent for us to use it; (b) if it is no longer necessary for us to use your Personal Data; (c) if you object to the use of your Personal Data and we don't have a good reason to continue to use it; or (d) if we haven't handled your Personal Data in accordance with our obligations.

No fee usually required

You will not have to pay a fee to access your Personal Data, or to exercise any of your other rights. However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. Alternatively we may refuse to comply with your request in these circumstances.

January 2023