PRIVACY & COOKIES POLICY PRIVACY NOTICE INTRODUCTION Web Services Integration Limited (Xceptor) is the operator and controller of www.xceptor.com (Website) and the following products and services: Xceptor products and services together referred to as Xceptor Connect: Our online training and certification content including tracking and reporting of user activity (Xceptor Academy) Our internet forum where users can hold conversations in the form of posted messages (Xceptor Huddle) Our documentation and resources repository (Xceptor Docs) Our training environment where users can practise using sample files provided in the Xceptor Academy and/or Xceptor LMS training courses (Xceptor Sandbox). Xceptor learning management system, an internet-based software application for the documentation, tracking, and reporting of training programs, classroom and online events, and training content accessible via https://academy.xceptor.com (Xceptor LMS). Xceptor software support services (Xceptor Support). Xceptor respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you use our Website and/or Xceptor Connect and tell you about your privacy rights and how the law protects you. For the purpose of this privacy notice, our Website, Xceptor Connect, Xceptor LMS, and Xceptor Support, and/or us providing other services to you will together be referred to as Xceptor Services. 1. IMPORTANT INFORMATION AND WHO WE ARE Purpose of this privacy notice This privacy notice aims to give you information on how Xceptor collects and processes your personal data through your use of Xceptor Services. Xceptor Services are not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing policy 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 privacy notice supplements other notices and privacy policies and is not intended to override them. Contact details Any requests to remove or update your data should be addressed to: support@xceptor.com where you need to update your Xceptor Connect or Xceptor LMS details and are receiving Xceptor Support services from us; and hello@xceptor.com where you need to unsubscribe from receiving marketing materials from us. You can also unsubscribe from marketing materials by following the unsubscribe link at the bottom of correspondence received. We have appointed IT Governance Europe Limited to act as our EU representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), or have any queries in relation to your EU rights or general privacy matters, please email our Representative at eurep@itgovernance.eu Please ensure to include our company name in any correspondence you send to our Representative. Any other questions about this privacy notice, including any requests to exercise your legal rights, please contact Xceptor’s legal team by send us an email at legalteam@xceptor.com or writing to Legal Team, Web Services Integration Limited, 85 Gresham Street, London EC2V 7NQ. 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. Changes to the privacy notice and your duty to inform us of changes We keep this privacy notice under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. We will endeavour to update your personal data within twenty (20) working days of any new or updated personal data being provided to us, in order to ensure that the personal data we hold about you is as accurate and up to date as possible. Third-party links Xceptor Services 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 the Xceptor Services, we encourage you to read the privacy policy of every website you visit. 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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: Identity Data includes name, user ID or similar identifier, name of company you work for or with, country of residence, company ID, job description/title, department, account type, and date of birth. Contact Data includes address, email address and telephone numbers. Financial Data includes bank account and payment details. Transaction Data includes details about payments to and from you, other details of products and services you have purchased from us, and if you contact us a record of that correspondence. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Xceptor Services. Profile Data includes your username and password preferences, purchases or orders made by you, your interests, preferences, feedback and survey responses. It also includes information you may disclose to any of our employees solely for the purpose of allowing us to develop a more personal relationship with you. Usage Data includes information about how you use our Xceptor Services. With regard to the Xceptor LMS and Xceptor Connect this may include course participation, course registration, attendance, course completion, and certification and assessment data. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific 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 privacy notice. 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. If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 3. HOW IS YOUR PERSONAL DATA COLLECTED? We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you; apply for our products or services; create an account on Xceptor Connect; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion or survey; or give us feedback or contact us. Automated technologies or interactions. As you interact with Xceptor Services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies 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 below for further details. We may also collect Technical Data about you from analytics providers, advertising networks, and search information providers. 4. 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 we need to perform the contract we are about to enter into or have entered into with you. 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 obligation. Please continue reading to find out more about the types of lawful basis that we will rely on to process your personal data. Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us. 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 register you as a new user Identity, Contact, and Profile data Performance of a contract To manage our relationship with you which will include notifying you about changes to our terms or privacy notice and asking you to leave a review or take a survey Identity, Contact, Profile, Usage and Marketing and Communications data Performance of a contract, necessary to comply with a legal obligation and/or necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) To process and deliver your order including manage payments, fees and charges and collect and recover money owed to us Identity, Contact, Financial, Transaction, and Marketing and Communications data Performance of a contract with you and/or necessary for our legitimate interests (to recover debts due to us) To administer and protect our business and that of Xceptor Group companies and Xceptor Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Identity, Contact, and Technical data 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) and/or necessary to comply with a legal obligation To enforce our rights under any contracts we have in place with you Identity, Contact, Profile, Usage, Technical, Financial, Transaction, and Marketing and Communications data Performance of a contract with you, 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) and/or (necessary to comply with a legal obligation To deliver relevant Xceptor Services content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Identity, Contact, Profile, Usage, Marketing and Communications, and Technical data Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) To use data analytics to improve Xceptor Services, marketing, customer relationships and experiences Technical and Usage data Necessary for our legitimate interests (to define types of customers for our products and services, to keep Xceptor Services updated and relevant, to develop our business and to inform our marketing strategy) To make suggestions and recommendations to you about services that may be of interest to you Identity, Contact, Profile, Usage, Technical, and Marketing and Communications data Necessary for our legitimate interests (to develop our products/services and grow our business) Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you or the business you represent have requested information from us or purchased services from us and you have not opted out of receiving that marketing. Third-party marketing We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. Opting out You can ask us or third parties to stop sending you marketing messages at any time by following the unsubscribe link at the bottom of correspondence received from us or emailing us at hello@xceptor.com. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. 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 some parts of the Xceptor Services may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy below. 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. DISCLOSURES OF YOUR PERSONAL DATA We may share your personal data with the parties set out below for the purposes set out in the table within the ‘Purposes for which we will use your personal data’ section above. Internal Third Parties as set out in the Glossary (section 10 of this privacy notice). External Third Parties as set out in the Glossary (section 10 of this privacy notice). Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 6. INTERNATIONAL TRANSFERS We share your personal data with affiliated companies of Xceptor (Xceptor Group). This will involve transferring your data outside the European Economic Area (EEA). We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules". For further details, see European Commission: Binding corporate rules [https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/binding-corporate-rules-bcr_en]. Some of our External Third Parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries [https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en]. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield [https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en]. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. 7. DATA SECURITY We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit 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 our instructions and they are subject to a duty of confidentiality. Where we have given you (or where you have chosen) a password which enables you to access Xceptor Service you are responsible for keeping this password confidential. 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. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Xceptor Services. Any transmission is at your own risk. Once we have received your information, we will use appropriate security measures to prevent unauthorised access. 8. DATA RETENTION How long will you use my personal data for? We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 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, regulatory, tax, accounting or other requirements. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see ‘Your legal rights’ (section 9 of this privacy notice) below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 9. YOUR LEGAL RIGHTS Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to: Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 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 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: If you want us to establish the data's accuracy. Where our use of the data is unlawful but you do not want us to erase it. 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. 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. Withdraw consent at any time 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. See ‘Contact Details’ (section 1 of this privacy notice) above for further information. 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 could 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 could 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. 10. GLOSSARY LAWFUL BASIS Legitimate Interest means 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. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. THIRD PARTIES Internal Third Parties Other companies in the Xceptor Group who are based in the US, Singapore and South Africa and provide support services. External Third Parties Service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf including but not limited to IT and system administration service, telemarketing, marketing, and despatch of corporate gift providers. Third party event organisers Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. HM Revenue & Customs, regulators and other authorities. .......... COOKIE POLICY Web Services Integration Limited (Xceptor) is the operator and controller of www.xceptor.com (Website) and the following: Xceptor products and services together referred to as Xceptor Connect: Our online training and certification content including tracking and reporting of user activity (Xceptor Academy) Our internet forum where users can hold conversations in the form of posted messages (Xceptor Huddle) Our documentation and resources repository (Xceptor Docs) Our training environment where users can practise using sample files provided in the Xceptor Academy and/or Xceptor LMS training courses (Xceptor Sandbox). Xceptor learning management system, an internet-based software application for the documentation, tracking, and reporting of training programs, classroom and online events, and training content accessible via https://academy.xceptor.com (Xceptor LMS). Xceptor software support services (Xceptor Support). For the purpose of this cookie policy, our Website, Xceptor Connect, Xceptor LMS, Xceptor Support, and/or us providing other services to you will together be referred to as Xceptor Services. Xceptor Services use cookies to distinguish you from other users of Xceptor Services. This helps us to provide you with a good experience when you browse Xceptor Services and allows us to improve our services. 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. You can find information about the cookies we use and the purposes for which we use them in the table below: CATEGORY COOKIE TYPE & PURPOSE Strictly necessary cookies These are cookies that are required for the operation of Xceptor Services. They include, for example, cookies that enable you to log into secure areas of our Xceptor Services. We use the following strictly necessary cookies for the Xceptor Connect service: - User - Used to provide user context to the Learning Records Store (LRS) - User Authentication - User authentication token cookie and cookie use during full-screen login to return data to the JavaScript application - User Email - Used during account creation - User Identity - Identify the user once he has logged in, for the duration of a session - User Login - Used for logging in users and authorization of a user session - User Logout - Logout inactive users after a period time - User Personalisation - Client theme personalization. Only used when “Make this my default theme on all my devices” unselected. - User Origin – Used to ensure users “stick” to a particular origin webserver for all requests - User Redirect - Used during login and SSO to redirect to the requested page - User Security - Detect and block cross-site request forgery (CSRF) for security purpose - Clear Notifications - Client clear notifications. - Developer - Developer only, used by rack-mini-profiler to bypass work - DOS Security - Temporary cookie that informs client denial of service protection is in place. - Full Screen Login - Full screen login client setting - Session cookie Analytical or performance and targeting cookies Analytical or performance cookies allow us to recognise and count the number of visitors and to see how visitors move around Xceptor Services when they are using it. This helps us to improve the way Xceptor Services work, for example, by ensuring that users are finding what they are looking for easily. Targeting cookies record your visit to the Xceptor Services, the pages you have visited and the links you have followed. We will use this information to make Xceptor Services more relevant to your interests. We may also share this information with third parties for this purpose. We use the following analytical, performance, or targeting cookies for the Xceptor Connect service: - User Interaction - Measure how users interact with website content - Google Analytics - Only set if configured to use GA We use the following third party analytical, performance or targeting cookies for the Website: - LinkedIn - Ads ID syncing. Expires in 30 days - Adroll - Used to identify the user across visits and devices - Bing Ads - tracking cookie used to engage with a user that has previously visited our Website - Hubspot – tracking cookie used to monitor a user’s total, first, current and last visit Functionality cookies These cookies allow our Xceptor Services to remember choices you make and provide more enhanced, personal features. These cookies cannot track your browsing activity on other websites. They do not gather any information about you that could be used for advertising or remembering where you have been on the Internet outside of our Xceptor Services. - Country – stores the user’s country preference - Language – stores the user’s language preference - Welcome banner – controls the visibility of the welcome banner on the Website Some cookies we use are from third party companies to provide us with web analytics and intelligence about Xceptor Services, such as those stated in the table above us. Please note that third parties may also use cookies, over which we have no control. For more information on how these companies collect and use information on our behalf and to deactivate third party cookies, please refer to their privacy policies. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Xceptor Services. hello@xceptor.com UK +44 (0)20 3427 3108 US +1 212 324 1452 SG +65 315 957 87 JOIN OUR MAILING LIST Company Careers Partners Media Relations Locations Sectors Capital Markets Securities Services Asset Management Insurance Policies Privacy & Cookies Legal T&Cs COVID-19 Stay connected © 2021 Web Services Integration Limited