Privacy & Cookie Policy

Privacy Policy

1. Introduction

We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we will explain how we collect, use and protect your personal data.

We will also explain what rights you have with regards to your personal data and how you can exercise those rights.

In this policy, "we", "us" and "our" refer to Xanthos Limited. For more information about us, see Section 6.

2. Collection of personal data

We collect personal data from you for one or more of the following purposes:

To provide you with information that you have requested or which we think may be relevant to a subject in which you have demonstrated an interest;
To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and services;
To fulfil a contract that we have entered into with you or with the entity that you represent;
To ensure the security and safe operation of our websites and underlying business infrastructure, and
To manage any communication between you and us.

The table in Section 3 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.

Technical information

In addition, and in order to ensure that each visitor to our website can use and navigate the site effectively, we collect the following:

Technical information, including the Internet Protocol (IP) address used to connect your device to the Internet;
Your browser type and version, time zone setting, browser plug-in types and versions;
Operating system and platform;
Information about your visit, including the Uniform Resource Locators (URL) clickstream to, through, and from our site.

Our cookies policy describes in detail how we use cookies.

In Section 5 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.

3. Lawful basis for the processing of personal data

The table below describes the various forms of personal data we collect and the lawful basis for processing this data. Our business architecture, accounting and systems infrastructure means that all personal data is processed on common platforms. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties and, where this happens, this is also identified below.

When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:

The purpose test – is there a legitimate interest behind the processing?
Necessity test – is the processing necessary for that purpose?
Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights or freedoms?

Information category	Data collected	Purpose for collection	Lawful basis for processing	Data shared with?	Retention period
Purpose of collection 1: To provide you with information
Subject matter information	Name, company name, geographic location, email address, business sector.	To provide appropriate online or email information about products or services that you have requested	Contractual fulfilment	Internally only	Maximum 7 years from the date the information is collected. 6 months if a marketing email is left unopened
		To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest.	Legitimate interest	Internally only
	Telephone number	Follow-up to ensure requested information meets needs and identify further requirements	Legitimate interest	Internally only
	Personal contact information as provided through website forms or at trade shows or any other means.	General mailing list subscription	Consent	Internally only
Purpose of collection 2: Internally only
Information category	Data collected	Purpose for collection	Lawful basis for processing	Data shared with?	Retention period
Transaction details	Name, physical address, email address, telephone number, bank account details (for credit accounts), other medium of content delivery	To process purchase transactions for products and services with customers, and to ensure any transaction issues can be dealt with.	Contractual performance	Internally only	Maximum 7 years from the date of the performance of the contract.
		For accounting and taxation purposes	Statutory obligation	Internally and professional advisers	7 years for VAT records from the performance of the contract
		Documentation should any contractual legal claim arise	Legitimate Interest	Internally and professional advisers
Payment card data	Primary account number (PAN), cardholder name, service code, expiration date	To pay for online advertising for you	Contractual performance	Suppliers only	Only retained whilst information is input into supplier’s interface.
Purpose of collection 3: Security
Information category	Data collected	Purpose for collection	Lawful basis for processing	Data shared with?	Retention period
Security information	Technical information, as described above, plus any other information that may be required for this purpose	To protect our websites and infrastructure from cyber-attack or other threats and to report and deal with any illegal acts.	Legitimate interest	Internally, forensic and other organisations with whom we might contract for this purpose.	Relevant statutes of limitation
Purpose of collection 4: Communications
Information category	Data collected	Purpose for collection	Lawful basis for processing	Data shared with?	Retention period
Contact information	Names, contact details, identification details	To communicate with you about any issue that you raise with us or which follows from an interaction between us.	Legitimate interest	Internally and, as necessary, with professional advisers.	Relevant statutes of limitation.

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 support@e-xanthos.co.uk 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:

The right to be informed

As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy policy and any related communications we may send you.

The right of access

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.

The right to rectification

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.

The right to erasure (the ‘right to be forgotten’)

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.

The right to restrict processing

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

The right to data portability

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.

The right to object

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

Any comments, questions or suggestions about this privacy policy or our handling of your personal data should be emailed to support@e-xanthos.co.uk

Alternatively, you can contact us using the following postal address or telephone numbers:

Xanthos Limited
Unit 2 Clive Court
Bartholomew’s Walk
Cambridgeshire Business Park
Ely
Cambridgeshire
CB7 4EA
United Kingdom

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.

7. Complaints

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.

9. Amendments

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.

Cookies Policy

We use cookies on our site for a number of purposes. They help us to provide you with a good experience when you browse our website and also allow us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that visitors find what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences.

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and more relevant to your interests. We may also share this information with third parties to display ads that will be relevant to you for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them below.

First-party (Xanthos Ltd) cookies

This website will set some cookies that are essential for the website to operate correctly. These cookies, none of which capture personally identifiable information, are as follows:

Visitor ID – this cookie is a numeric value that identifies unique visitors and provides coherence and consistency to a site visit;

Page Number – this cookie identifies the page you are on;

Session ID – this cookie identifies your website session;

Third-party cookies

Our website will set several types of third-party cookies, and we do not control the operation of any of them. The third-party cookies which may be set include:

Google Analytics – we use Google Analytics to collect data about website usage. This data does not include personally identifiable information. You can view the Google Privacy Policy here: www.google.com/policies/privacy/

AddThis – the AddThis cookie is used when you use the ShareThis service on our website to share a link with LinkedIn, Facebook, Twitter, etc. You can read the AddThis Privacy Policy here: http://www.addthis.com/privacy/privacy-policy

Google Remarketing – we use Google’s Remarketing cookie to market products and services we think may be of interest to you. You may see our adverts on Google’s Display Advertising Network of partner websites and Google’s own search results pages. We aim to carefully select the products and services we remarket to you and do so based on the pages you have visited on our website.

SharpSpring - we use SharpSpring’s IP Address tracking technology to identify businesses visiting our site and the pages that are being used. This helps us analyse data about web page traffic in order to develop and improve our website for business visitors. We also use SharpSpring cookies to run campaigns and to track visitor information. The cookies track goals completed by the visitor and determine whether a visitor is part of a campaign. You can read the SharpSpring Privacy Policy here: https://sharpspring.com/legal/privacy/

Facebook – we use a Facebook pixel to obtain information regarding the activities that visitors engage in while visiting our web pages. For information on Facebook’s Privacy and Cookie policy, visit https://www.facebook.com/privacy/explanation

Hotjar – we use Hotjar to analyse visitor behavior on our website in order to improve the experience for the visitor. For information on Hotjar’s Privacy policy, visit https://www.hotjar.com/legal/policies/privacy

Managing Cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.