4. Storage of personal data
Xanthos Limited is a UK-domiciled organisation with offices in the UK.
Our website is hosted in the UK and is accessed only by our UK-based staff.
Our customer relationship management, marketing, project management and accounting systems for all our businesses are either UK-based or hosted by companies participating in the EU - U.S. Privacy Shield Framework .
We use Cloud Service Providers (CSPs) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.
Unless we specifically state otherwise all of the CSPs that we use utilise EU-located processing facilities.
We provide hosting for clients through partners that are based in the EU. We are a data processor in respect of hosting and the client is the data controller.
For some web development we use contractors based outside of the EU. We have standard contractual clauses in place with those contractors.
Our banking arrangements are based in the UK.
We resell products supplied by organisations outside the EU. This may mean that our resale partner will have access to information about data subjects who purchase their products.
We operate a data retention policy in respect of all data, whether paper-based or digital and those aspects of it which relate to personal data are contained in the table at 3, above.
5. Your rights as a data subject
As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email firstname.lastname@example.org or use the information supplied in the Contact us section below. In order to process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:
You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
a) The purposes of the processing
b) The categories of personal data concerned
c) The recipients to whom the personal data has been disclosed
d) The retention period or envisioned retention period for that personal data
e) When personal data has been collected from a third party, the source of the personal data
If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.
When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
a) The accuracy of the personal data is contested
b) Processing of the personal data is unlawful
c) We no longer need the personal data for processing but the personal data is required for part of a legal process
d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing
You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.
You have the right to object to our processing of your data where
Processing is based on legitimate interest;
Processing is for the purpose of direct marketing;
Processing is for the purposes of scientific or historic research;
Processing involves automated decision-making and profiling.
6. Contact us
Alternatively, you can contact us using the following postal address or telephone numbers:
St John's Innovation Centre
Telephone: +44 333 456 0068
Our telephone switchboard is open 9:00 am – 5:30 pm GMT, Monday to Friday. Our switchboard team will take a message and ensure the appropriate person responds as soon as possible.
Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.
Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union. For the United Kingdom, this is the Information Commissioner’s Office (ICO), who is also our lead supervisory authority. Its contact information can be found at https://ico.org.uk/global/contact-us/
8. 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 all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
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.
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We will notify you of significant changes to this policy by email.
10. Acting as a data processor
In respect of hosting and digital marketing, we do not act as a data controller; instead, we act as a data processor.
Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.