Privacy & Cookie Policy | Exinity Group

Privacy Policy

Your Personal Data is Protected

Commitment

Exinity Works UK Ltd (referred to as "we" "us" "our" "Exinity") is committed to protecting your personal information and respects its’ Clients’ expectations on privacy and confidentiality. This policy statement will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. We are committed to safeguard any information we collect, use and hold about you.

1. Important Information and who we are

Purpose of this policy statement

This policy statement aims to give you information on how Exinity Works UK Ltd collects and processes your personal data through your use of this website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this policy statement together with any other policy statement or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This policy statement supplements the other notices and is not intended to override them.

Controller

Exinity Works UK Ltd is the controller and responsible for your personal data.

If you have any questions about this policy statement, including any requests to exercise your legal rights, please contact the Data Protection Department using the details set out below.

Contact Details

Data Protection Department
Email: [email protected]
Postal Address: 1 St Katharine's Way, London, E1W 1UN, United Kingdom.
Telephone number: +44 (0) 20 3514 1251

You have the right to feel confident that Exinity Works UK Ltd will handle your personal information responsibly and in line with good practice. If you have a concern about the way we are handling your information we will take your concern seriously and work with you resolve it.

If you feel that we have not fully addressed and resolved your concerns then you can contact the Information Commissioner Office on 0303 123 1113. Additional contact details can be found on their website at https://ico.org.uk/concerns/.

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

We may modify or amend this policy statement from time to time. We will notify you appropriately when we make changes to this privacy statement. We do however encourage you to review this statement periodically so as to be always informed about how we are processing and protecting your personal information.

2. The Data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect basic information from visitors to our website and we may collect, use, store and transfer different kinds of personal data about you as per below:

Identification data: includes name, surname
Contact data: email address, phone
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website.

Non-Personal Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy statement.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions:
- Subscribe to our contact us form;
Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, [server logs] and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy here for further details.

4. Disclosures of personal data

We will not share your data with any third party.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
When you have provided your consent to do so.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy	(a) Identity (b) Contact (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
	(a) Identity (b) Contact (c) Profile (d) Usage	(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that you can still access this website and it will function properly. Cookies are used on this website in order to offer our users a more customized browsing experience.

For more information about the cookies we use, please see our Cookie Policy.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Technical and Operational Security Measures

Exinity Works UK Ltd has put in place appropriate security measures to protect the security of your personal data and prevent any unauthorized or unlawful processing, accidental loss, destruction, alteration, disclosure or damage on personal data. Exinity Works UK Ltd implements appropriate technical and organisational measures such as network traffic encryption, pseudonymization, data encryption, two-factor authentication, access management procedure, tokenization, clean desk policy, business continuity and disaster recovery, IT systems risk assessment, physical and logical access segregation, process in case of personal data breach policy etc. Exinity Works UK Ltd limits access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on Exinity Works UK Ltd’s instructions and they are subject to a duty of confidentiality.

Details of these measures are available upon request. In addition, Exinity Works UK Ltd, has put in place procedures to deal with any suspected data security breach and will notify data subjectst and any applicable regulator of a suspected breach where Exinity Works UK Ltd is legally required to do so.

6. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by Contacting us.

7. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to withdraw consent where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact us.

No fee usually required

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

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. Personal Data Breach

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. If you require further information on how we deal with a Data Breach please Contact us.

9. Questions

If you have any questions which have not been covered in this Policy Statement, or any further concerns regarding the use of Personal Data, please do not hesitate to Contact us.

10. Your right to complain

If you have a complaint about our use of your information, you can contact the the Information Commissioner Office on 0303 123 1113. Additional contact details can be found on their website at https://ico.org.uk/global/contact-us

11. Glossary

"Comply with a legal or regulatory obligation": means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. "GDPR": shall mean the EU General Data Protection Regulation 2016/679;

"Legitimate Interest": shall mean the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.

"Performance of Contract": means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

"Personal data breach": means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

Enjoy a More Customized Web Browsing Experience

Cookies explained

Cookies are small pieces of information that are stored on your computer by a website you visit in order to enable you to perform certain functions on the website and regulate its content to your preference. They can store data on pages which you have provided key information for (e.g. when you provide a password) but only once you are asked and you accept to the storage of this information. Cookies may be used on some pages of the site for us to provide website users with a more customized web browsing experience; they are not used to determine the personal identity of anyone merely visiting the site.

Change your consent

What kind of cookies we use

Session cookies

These cookies are temporary cookies as they are deleted as soon as you close your browser. Session cookies are used to retain the information you provide us with as you navigate through each section of our website.

You can choose to decline session cookies via your browser’s privacy settings but please note that this may have a negative impact on your browsing experience and particularly if these are declined across all websites.

Analytical cookies

Analytical cookies may include both temporary and more persistent cookies that we use to track how you use our website and for how long. Analytical cookies do not divulge any identifying information specific to your person but they do help us improve how we provide you with our content.

Refer to your browser’s privacy settings on how you can opt-out of analytical cookies.

Functional cookies

Functional cookies record and save your choices in order to provide for a more seamless experience across our website. One-way functional cookies do this is by remembering your language selection each time you visit us.

Refer to your browser’s urgent privacy settings on how you can opt-out of functional cookies.

Third Party cookies

These cookies are used by third parties and mostly by social media websites like Google+, Facebook or YouTube. Third Party cookies allow us to offer you easy ways to share our content throughout your social media and also present you with the videos we post on YouTube.

You can disable the use of these cookies through your browser’s privacy settings but please do note that this will also disable all the functions described above.

Targeting Cookies or advertising Cookies

These cookies are used to deliver advertisements tailored to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.

You can disable the use of these cookies through your browser’s privacy settings.

Cookie disclosure table:

Name	Provider	Purpose	Expiry	Type
_dc_gtm_UA-#	exinity.com	Used by Google Tag Manager to control the loading of a Google Analytics script tag.	1 day	HTTP Cookie
_ga	exinity.com	Registers a unique ID that is used to generate statistical data on how the visitor uses the website.	2 years	HTTP Cookie
_gat	exinity.com	Used by Google Analytics to throttle request rate.	1 day	HTTP Cookie
_gid	exinity.com	Registers a unique ID that is used to generate statistical data on how the visitor uses the website.	1 day	HTTP Cookie
collect	google-analytics.com	Used to send data to Google Analytics about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels.	Session	Pixel Tracker
__cfduid	exinity.com	Used by the content network, Cloudflare, to identify trusted web traffic.	29 days	HTTP Cookie
CookieConsent	group.exinity.com	Stores the user's cookie consent state for the current domain.	1 year	HTTP Cookie
ads/ga-audiences	google.com	Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's online behaviour across websites.	Session	Pixel Tracker
wmc	workable.com	Used to store information regarding the application domain.	10 years	HTTP Cookie

Why we use cookies

As already mentioned, we use cookies to ensure the optimal functionality of our website and cater our content to your personal preferences.

Please read our Privacy policy for more detailed information on how we use your data. If you have further questions please do not hesitate to Contact us.

Further information

For more information on cookies and their use, please visit the Information Commissioners Office in the UK at: https://ico.org.uk/global/cookies/.

Marketing and Communication Policy Statement

This marketing and communication policy statement tells you about the information we collect from you when you sign up in order to be contacted by Exinity Works UK Ltd for marketing purposes as described below. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.

Who are we?

Our company name is Exinity Works UK Ltd.

Our address is: 1 St Katharine's Way, London, E1W 1UN, United Kingdom.

Any enquiries about our use of your personal data should be addressed to the below contact details:

Data Protection Team
Email: [email protected]
Phone number: +44 (0) 20 3514 1251

What personal data do we collect?

We collect information you provide directly to us in the contact form, like name, surname, email, address and country of residence and IP addresses.

Why do we collect this information?

We will use your information to contact you in response of any inquiry you might complete on our contact form.

We ask for your consent to do this, and we will only contact you in response to a message you have sent us via our contact us form and for as long as you continue to consent.

What means of communication do we use?

We may use your information in order to respond in your inquiry by various communication means like phone and email and any other means available for communication between us and you and not forbidden by the applicable legislation.

What do we do with your information?

Shared Data

Your information is stored in our database and we do not share your personal information with third parties outside of Exinity Works UK Ltd except in the following cases as and if applicable:

a) with selected trusted third-parties with whom we work closely and help parts of our business operations and provide:

- cloud and IT hosting services; - mobile acquisition networks for the performance of mobile application campaigns; - marketing automating platforms services; in order to send you relevant targeted marketing communications and advertisements that are more relevant to you;

b) with social media like Facebook, Twitter, LinkedIn, You-Tube and advertising platforms like Google in order to create similar audience and show you advertising on different platforms; The information shared with these platforms is pseudonymised to protect your personal data.

Your information is processed based on our instructions and we use the third-party providers to process your information on our behalf. The third-party service provider is only entitled to process your personal data in accordance with our instructions and in compliance with our Privacy Policy.

Automated Decision Processing and Profiling

We use pixels (pieces of java code) to read your actions in the website and mobile applications, cookies and IP address information, your personal and demographic data and visits in our website and mobile applications,. For more information about our use of cookies and how to opt out in order not to receive these please follow the link here.

During these processes, Exinity Works UK Ltd takes all the technical and operational measures to correct inaccuracies and minimize the risk of errors and to secure your personal data.

How long do we keep your information for?

Your information is kept for as long as you continue to consent to keep your personal data.

Your rights over your information

By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate.

You can also ask for it to be erased and you can ask for us to give you a copy of the information. You can also ask us to stop using your information – the simplest way to do this is to withdraw your consent, which you can do at any time. You can do this:

By emailing [email protected] or
By calling +442038070150

Once we receive your request for deletion of your data, your request will be processed within 30 days from the day of receipt of your request.

Your right to complain

You have the right to feel confident that Exinity Works UK Ltd will handle your personal information responsibly and in line with good practice.

If you have a concern about the way we are handling your information we will take your concern seriously and work with you resolve it. Please feel free to use the template provided by the Information Commissioners Office in the UK to highlight and raise your concern with us. This can be found at: https://ico.org.uk/for-the-public/raising-concerns/. The link provided above also gives guidance to follow when raising your concern.