Privacy policy test
Version: 1.5
Effective from: 24.05.2023
General
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This Privacy Policy informs You regarding xpate LTD policy regarding the collection, use, and disclosure of personal data when You use the Company’s service and the choices You have associated with that data.
Definitions:
Policy – this Privacy Policy of xpate LTD
Company, we, us, our – xpate LTD, incorporated in England (registration number 11920779, registered address: Level 18, 40 Bank Street, Canary Wharf, London, England, E14 5NR)
UK GDPR – UK General Data Protection Regulation
EU GDPR – EU General Data Protection Regulation
You, Your – an identified or identifiable individual (i.e. a Data Subject as defined in the UK GDPR, EU GDPR, UK Data Protection Act 2018 as applicable) who is applying, accessing or using xpate services either on his or her own account or on behalf of a corporate entity. This includes an individual acting as an existing customer or as a prospective customer of xpate, or an individual acting on behalf of a corporate entity, including any principals (managing and financial directors, other directors and officers, shareholders, partners and beneficial owners of the corporate entity), as well as any member of staff or an employee accessing or using xpate services on behalf of a corporate entity.
EEA – European Economic Area
Websites – the xpate website at www.xpate.com and other websites of xpate products and services
xpate group – the group of companies affiliated or otherwise partnered with xpate LTD
xpate LTD is a personal data Controller as defined in the UK GDPR, the UK Data Protection Act 2018 and EU GDPR. Company is entitled to process and to contract a processor to process personal data of Data Subjects on behalf of Company.
Company’s customers’ personal data security is the first priority for Company, and the Company fully complies with all the applicable laws and regulations. This Policy applies to the personal data processing activities of xpate LTD. Your personal data may be transferred to and processed at a destination outside the United Kingdom and the EEA including countries that have different data protection rules than Your country. It may also be processed by Company’s staff or staff of xpate’s service providers operating outside the United Kingdom and the EEA. By using xpate products and services and accepting this Policy, You consent to Your personal data being transferred to other countries.
For any inquires or additional information in relation to this Policy, please contact our Data Protection Officer at:
xpate LTD
Address: Level 18, 40 Bank Street, Canary Wharf, London, England, E14 5NR
E-mail: dpo@xpate.com
We collect and process personal data about You in various instances, including but not limited to the following:
Registration and contact forms on Websites
If You wish to establish a business relationship with us, find out more about our services or if you have any other question for us, You may be asked or offered to fill out an electronic application or registration form on our Websites with your initial identity and contact information. We also collect Your electronic device information at that time.
Website visits
When You visit xpate Websites, we collect information about Your activity with the help of cookies or equivalent technologies. Device information such as browser’s identifier, the Website’s visiting frequency, average time spent on the Website and viewed pages is collected. Such information is collected with the purpose of evaluating the attractiveness of our Websites and to improve their content and functionality.
Cookies are informational files that identify a computer or a mobile device that You use to access our Websites or use our services. We use both first party cookies (cookies for which the provider is xpate as the owner of Website domains) and third party cookies (cookies for which the provider is a third party such as one providing a service to xpate or conducting analytics or advertising activities). More information about the cookie files used by xpate can be found in xpate’s Cookie Policy.
Entering Your account with xpate
When You enter your xpate online account as a customer, we may obtain personal data to identify You from other visitors of the Website. Data such as device and browser information are collected at that time.
Using xpate services
We collect and process information about You while You are using our services, for example, by verifying Your identity, correcting Your contact details, managing Your payment details, processing Your payments, ensuring the security of Your account and our services.
Communication with xpate
We collect information when You communicate to us via email, phone call, Live Chat, Websites and other means. We also process Your personal information when we are contacting You.
Customer surveys
When You participate in our customer survey, we will store the involved personal information.
3.1. Information You give us
You may give us information about Yourself when You use our services, contact us, or in other way. Please note that You are only allowed to provide Your own personal data when using the services unless legally authorised otherwise, for the services to be provided correctly.
We will be informing You regarding the specific data that is required for us to collect from You in accordance with the reasonable steps that need to be taken in the course of establishing a business relationship with You or providing a service that You wish to use. The data collected at each stage shall be proportionate to the services we provide to You and the data collection purposes at the time.
We may collect personal data from You directly in the course of establishing a business relationship or providing a service based on the following types of requirement:
Legal requirement
This is a requirement that is placed on us by the applicable legislation. If You fail to provide this data category to us, it may prevent us from being able to enter into a business relationship with You or may force us to end our business relationship with You unilaterally.
Requirement to enter into contract
This applies to personal data that is needed in order for us to enter into a business relationship with You. Your failure to provide this data category to us may prevent us from being able to enter into a business relationship with You.
Contractual requirement
Personal data covered by this requirement ensures our ability to maintain our business relationship with You. Your failure to provide this data category may force us to end our business relationship with You unilaterally.
Depending on which Service You choose to use, this personal data will be:
You may, at Your sole discretion, choose to provide us with additional information about You which constitutes “special categories” of personal data according to the UK GDPR and the EU GDPR, including e.g. data revealing religious, political or philosophical beliefs, trade union membership, or data concerning health, sex life or sexual orientation. We will never require this additional information from You in order to provide You with our Services. Providing us with this additional information will be strictly voluntary and based on Your explicit consent. Please see sections 9 and 10.7 of the present Policy for information about how You can revoke Your consent.
You can at any time change Your profile information such as Your contact information and other editable settings. This can be done by contacting us.
3.2. Information we collect about You from third parties
We may collect Your personal data in the course of establishing a business relationship or providing a service from or with the help of the categories of third parties listed below. Exactly which third parties are involved and for which purposes will depend on which service You use; therefore, collection of data from third parties is subject to section 4. Purpose and legal basis of personal data processing of the present Policy.
When we collect Your personal data from or via third parties, we take all reasonable contractual, legal, technical, and organisational measures to ensure that Your personal data is processed with an adequate level of protection and in accordance with applicable law. The data collected shall be proportionate to the services we provide to You and the data collection purposes at any given time.
Suppliers and subcontractors that we use for the fulfillment of our commitments arising from the provision our services to You such as communications service providers, IT service providers, payment service providers and financial institutions when provision of our service to You requires involvement of such providers
Outsourced service providers that we use for the provision of our services including but not limited to identity verification services, fraud prevention services, money laundering prevention services
xpate group - Your information may be shared with companies within the xpate group, based on xpate’s legitimate interest to conduct its business.
Third parties taking legal actions in connection with debt collection on our behalf (for instance, debt collectors, lawyers, court bailiffs, insolvency administrators and other persons acting in accordance with the applicable laws)
Our legal, accounting and auditing service providers
Government authorities and institutions, regulators, law enforcement bodies
Government information systems such as population registers, state social insurance agencies etc. in accordance with the applicable legislation
3rd parties that You ask us to disclose or consent to us disclosing Your personal data to
Your legal representative
Social networks
Public information sources
Depending on which services You choose to use, we may collect the following information about You in the course of the business reilationship, either ourselves or via third parties (for example, credit and fraud prevention agencies, products/services, or public databases):
Contact and identification information – audio recordings, photos and video recordings of You and Your ID card etc.
Biometric information – video, photo data of You that is collected during Your identity verification when using our services and may be processed via our specialized service providers
Information on orders – details about the goods/services You purchase or order including, for example, type of goods or shipment tracking number
Financial information – financial information collected from third parties such as Your income, potential credit commitments, negative payment remarks etc.
Transaction information - xpate saves Your information such as transaction type, transaction amount, Your identifying information (such as IBAN, name, email, address) for the purpose of implementing Company’s services
Information about the interaction between You and xpate – how You use the services, including information on outstanding and historical debts; technical data such as page response times, download errors, personal preferences; Your interactions with our customer service, etc.
Recorded conversations – we record telephone conversations if You call our customer service and web-site chats, and sometimes when we call You, if we inform You about this at the start of the call.
Device information – e.g. IP address, language settings, browser settings, time zone settings, operating system and platform and screen resolution.
Information from external sanctions lists and PEP lists – we may screen Your information against lists of persons subject to sanctions, and lists of persons who are Politically Exposed Persons. These lists include information such as name, date of birth, place of birth, occupation or position and reason for being listed.
Service-specific information – in order to provide You with some of our services we may collect and process additional personal data that is not covered by the above categories.
Purpose and legal basis of personal data processing
4.1. General information on purpose
xpate must have a legal basis (a valid legal reason) for processing Your personal information A valid legal basis can be any of the following:
Fulfil contractual obligations
We need certain personal information to provide our services and cannot provide them without this information.
Comply with laws
In some cases, xpate have a legal responsibility to collect and store Your personal information (for example, under money-laundering laws we must hold certain information about our customers).
Version: 1.5
Effective from: 24.05.2023
General
Subtittle
Bulleted
List
List
List
Numbered
One
Two
Three
Table
File
This Privacy Policy informs You regarding xpate LTD policy regarding the collection, use, and disclosure of personal data when You use the Company’s service and the choices You have associated with that data.
Definitions:
Policy – this Privacy Policy of xpate LTD
Company, we, us, our – xpate LTD, incorporated in England (registration number 11920779, registered address: Level 18, 40 Bank Street, Canary Wharf, London, England, E14 5NR)
UK GDPR – UK General Data Protection Regulation
EU GDPR – EU General Data Protection Regulation
You, Your – an identified or identifiable individual (i.e. a Data Subject as defined in the UK GDPR, EU GDPR, UK Data Protection Act 2018 as applicable) who is applying, accessing or using xpate services either on his or her own account or on behalf of a corporate entity. This includes an individual acting as an existing customer or as a prospective customer of xpate, or an individual acting on behalf of a corporate entity, including any principals (managing and financial directors, other directors and officers, shareholders, partners and beneficial owners of the corporate entity), as well as any member of staff or an employee accessing or using xpate services on behalf of a corporate entity.
EEA – European Economic Area
Websites – the xpate website at www.xpate.com and other websites of xpate products and services
xpate group – the group of companies affiliated or otherwise partnered with xpate LTD
xpate LTD is a personal data Controller as defined in the UK GDPR, the UK Data Protection Act 2018 and EU GDPR. Company is entitled to process and to contract a processor to process personal data of Data Subjects on behalf of Company.
Company’s customers’ personal data security is the first priority for Company, and the Company fully complies with all the applicable laws and regulations. This Policy applies to the personal data processing activities of xpate LTD. Your personal data may be transferred to and processed at a destination outside the United Kingdom and the EEA including countries that have different data protection rules than Your country. It may also be processed by Company’s staff or staff of xpate’s service providers operating outside the United Kingdom and the EEA. By using xpate products and services and accepting this Policy, You consent to Your personal data being transferred to other countries.
For any inquires or additional information in relation to this Policy, please contact our Data Protection Officer at:
xpate LTD
Address: Level 18, 40 Bank Street, Canary Wharf, London, England, E14 5NR
E-mail: dpo@xpate.com
We collect and process personal data about You in various instances, including but not limited to the following:
Registration and contact forms on Websites
If You wish to establish a business relationship with us, find out more about our services or if you have any other question for us, You may be asked or offered to fill out an electronic application or registration form on our Websites with your initial identity and contact information. We also collect Your electronic device information at that time.
Website visits
When You visit xpate Websites, we collect information about Your activity with the help of cookies or equivalent technologies. Device information such as browser’s identifier, the Website’s visiting frequency, average time spent on the Website and viewed pages is collected. Such information is collected with the purpose of evaluating the attractiveness of our Websites and to improve their content and functionality.
Cookies are informational files that identify a computer or a mobile device that You use to access our Websites or use our services. We use both first party cookies (cookies for which the provider is xpate as the owner of Website domains) and third party cookies (cookies for which the provider is a third party such as one providing a service to xpate or conducting analytics or advertising activities). More information about the cookie files used by xpate can be found in xpate’s Cookie Policy.
Entering Your account with xpate
When You enter your xpate online account as a customer, we may obtain personal data to identify You from other visitors of the Website. Data such as device and browser information are collected at that time.
Using xpate services
We collect and process information about You while You are using our services, for example, by verifying Your identity, correcting Your contact details, managing Your payment details, processing Your payments, ensuring the security of Your account and our services.
Communication with xpate
We collect information when You communicate to us via email, phone call, Live Chat, Websites and other means. We also process Your personal information when we are contacting You.
Customer surveys
When You participate in our customer survey, we will store the involved personal information.
3.1. Information You give us
You may give us information about Yourself when You use our services, contact us, or in other way. Please note that You are only allowed to provide Your own personal data when using the services unless legally authorised otherwise, for the services to be provided correctly.
We will be informing You regarding the specific data that is required for us to collect from You in accordance with the reasonable steps that need to be taken in the course of establishing a business relationship with You or providing a service that You wish to use. The data collected at each stage shall be proportionate to the services we provide to You and the data collection purposes at the time.
We may collect personal data from You directly in the course of establishing a business relationship or providing a service based on the following types of requirement:
Legal requirement
This is a requirement that is placed on us by the applicable legislation. If You fail to provide this data category to us, it may prevent us from being able to enter into a business relationship with You or may force us to end our business relationship with You unilaterally.
Requirement to enter into contract
This applies to personal data that is needed in order for us to enter into a business relationship with You. Your failure to provide this data category to us may prevent us from being able to enter into a business relationship with You.
Contractual requirement
Personal data covered by this requirement ensures our ability to maintain our business relationship with You. Your failure to provide this data category may force us to end our business relationship with You unilaterally.
Depending on which Service You choose to use, this personal data will be:
You may, at Your sole discretion, choose to provide us with additional information about You which constitutes “special categories” of personal data according to the UK GDPR and the EU GDPR, including e.g. data revealing religious, political or philosophical beliefs, trade union membership, or data concerning health, sex life or sexual orientation. We will never require this additional information from You in order to provide You with our Services. Providing us with this additional information will be strictly voluntary and based on Your explicit consent. Please see sections 9 and 10.7 of the present Policy for information about how You can revoke Your consent.
You can at any time change Your profile information such as Your contact information and other editable settings. This can be done by contacting us.
3.2. Information we collect about You from third parties
We may collect Your personal data in the course of establishing a business relationship or providing a service from or with the help of the categories of third parties listed below. Exactly which third parties are involved and for which purposes will depend on which service You use; therefore, collection of data from third parties is subject to section 4. Purpose and legal basis of personal data processing of the present Policy.
When we collect Your personal data from or via third parties, we take all reasonable contractual, legal, technical, and organisational measures to ensure that Your personal data is processed with an adequate level of protection and in accordance with applicable law. The data collected shall be proportionate to the services we provide to You and the data collection purposes at any given time.
Suppliers and subcontractors that we use for the fulfillment of our commitments arising from the provision our services to You such as communications service providers, IT service providers, payment service providers and financial institutions when provision of our service to You requires involvement of such providers
Outsourced service providers that we use for the provision of our services including but not limited to identity verification services, fraud prevention services, money laundering prevention services
xpate group - Your information may be shared with companies within the xpate group, based on xpate’s legitimate interest to conduct its business.
Third parties taking legal actions in connection with debt collection on our behalf (for instance, debt collectors, lawyers, court bailiffs, insolvency administrators and other persons acting in accordance with the applicable laws)
Our legal, accounting and auditing service providers
Government authorities and institutions, regulators, law enforcement bodies
Government information systems such as population registers, state social insurance agencies etc. in accordance with the applicable legislation
3rd parties that You ask us to disclose or consent to us disclosing Your personal data to
Your legal representative
Social networks
Public information sources
Depending on which services You choose to use, we may collect the following information about You in the course of the business reilationship, either ourselves or via third parties (for example, credit and fraud prevention agencies, products/services, or public databases):
Contact and identification information – audio recordings, photos and video recordings of You and Your ID card etc.
Biometric information – video, photo data of You that is collected during Your identity verification when using our services and may be processed via our specialized service providers
Information on orders – details about the goods/services You purchase or order including, for example, type of goods or shipment tracking number
Financial information – financial information collected from third parties such as Your income, potential credit commitments, negative payment remarks etc.
Transaction information - xpate saves Your information such as transaction type, transaction amount, Your identifying information (such as IBAN, name, email, address) for the purpose of implementing Company’s services
Information about the interaction between You and xpate – how You use the services, including information on outstanding and historical debts; technical data such as page response times, download errors, personal preferences; Your interactions with our customer service, etc.
Recorded conversations – we record telephone conversations if You call our customer service and web-site chats, and sometimes when we call You, if we inform You about this at the start of the call.
Device information – e.g. IP address, language settings, browser settings, time zone settings, operating system and platform and screen resolution.
Information from external sanctions lists and PEP lists – we may screen Your information against lists of persons subject to sanctions, and lists of persons who are Politically Exposed Persons. These lists include information such as name, date of birth, place of birth, occupation or position and reason for being listed.
Service-specific information – in order to provide You with some of our services we may collect and process additional personal data that is not covered by the above categories.
Purpose and legal basis of personal data processing
4.1. General information on purpose
xpate must have a legal basis (a valid legal reason) for processing Your personal information A valid legal basis can be any of the following:
Fulfil contractual obligations
We need certain personal information to provide our services and cannot provide them without this information.
Comply with laws
In some cases, xpate have a legal responsibility to collect and store Your personal information (for example, under money-laundering laws we must hold certain information about our customers).