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PRIVACY POLICY

Data Classification: Public

GENERAL INFORMATION

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eXate respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our Website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

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This notice is layered so you can click through to the specific areas in which you are interested.

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  • Who we are

  • Data Protection Officer (and how you can contact them)

  • Your data protection rights

  • Your responsibility to provide accurate information

  • Links to other website

  • Your right to complain

  • What Data we collect

  • Changes to this Privacy Notice
     

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1. WHO WE ARE

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eXate Technology Limited (company number 09512030) (collectively referred to as “eXate”, “we“, “us” or “our” in this privacy policy) is a data processor in respect of personal data provided by our clients and suppliers.

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When you visit our website http://www.exate.com, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Sites and our services.

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This privacy notice applies to all information collected through our website (such as http://www.exate.com), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy notice as the "Services").

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Please read this privacy notice carefully as it will help you make informed decisions about sharing your personal information with us.

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We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below. 

 

eXate is certified in both ISO 27001 and ISO 27701.

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2. DATA PROTECTION OFFICER

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Our Data Protection Officer is Sonal Rattan. She is responsible for overseeing data protection across eXate. 

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You can contact Sonal at:

Post: Data Protection Officer, 85 Great Portland Street, London, England, W1W 7LT

Email: dpo@exate.com 

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3. YOUR DATA PROTECTION RIGHTS

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Under data protection law, you have certain rights about the way we use your information. The rights available to you depend on our reason for processing your information. More information about the scope of these rights can be found on the Information Commissioner’s Office’s website: www.ico.org.uk.

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You are not usually required to pay any charge for exercising your rights, and we usually have one month in which to respond to you (unless your request is unusually complex).

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Please contact us at dpo@exate.com if you wish to make a request.

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Your right of access

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You have the right to ask us for copies of your personal information.

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You can read more about this right on the ICO’s website: https://ico.org.uk/your-data-matters/your-right-of-access/.

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Your right to get your data corrected

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You have the right to ask us to correct information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete

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You can read more about this right on the ICO’s website: https://ico.org.uk/your-data-matters/your-right-to-get-your-data-corrected/.

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Your right to get your data deleted 

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You have the right to ask us to erase your personal information in certain circumstances for example where we rely on your consent to use your information or where our purpose for using your information has come to an end. 

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You can read more about this right on the ICO’s website: https://ico.org.uk/your-data-matters/your-right-to-get-your-data-deleted/

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Your right to limit how we use your data

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You have the right to ask us to restrict our use of your information.

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You can read more about this right on the ICO’s website: https://ico.org.uk/your-data-matters/your-right-to-limit-how-organisations-use-your-data/.

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Your right to object to processing

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You have the right to object to our use of your personal data. This right may also require us to stop sending your marketing communication. 

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You can read more about this right on the ICO’s website: https://ico.org.uk/your-data-matters/the-right-to-object-to-the-use-of-your-data.

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Your right to data portability

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This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.

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You can read more about this right on the ICO’s website: https://ico.org.uk/your-data-matters/your-right-to-data-portability/.

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4. YOUR RESPONSIBILITY TO PROVIDE ACCURATE INFORMATION

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It is important that any information you provide directly to us is accurate and correct. Please let us know as soon as you can if any information we hold about you is no longer correct. 

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Providing false or inaccurate information in order to obtain a product or service may also result in services being restricted or cancelled. 

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5. LINKS TO OTHER WEBSITES

 

Where we provide you with links to the websites of other organisations, our privacy notice does not cover how the other organisations will use your data. It’s a good idea to read their privacy notice too. 

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6. YOUR RIGHT TO COMPLAIN

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We take our responsibility to look after your data very seriously. If you have any questions about our use of your data, or wish to make a complaint, please contact our Data Protection Team by emailing dpo@exate.com and we’ll be happy to answer your questions. 

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You also have the right to make a complaint about the way we use your information to the Information Commissioner’s Office. You can make a complaint to the ICO by calling 0303 123 1113 or visiting their website: https://ico.org.uk/make-a-complaint/.  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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7. HOW WE USE YOUR INFORMATION

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7.1. WHAT INFORMATION DO WE COLLECT?

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Information automatically collected

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In Short:   Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Services.

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We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

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Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookies Policy: http://www.exate.com/cookie-policy

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7.2. HOW DO WE USE YOUR INFORMATION?

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In Short:  We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

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We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

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We use the information we collect or receive:

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  • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
     

  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

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7.3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

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In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfil business obligations.

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We may process or share data based on the following legal basis:

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  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
     

  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
     

  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
     

  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
     

  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
     

More specifically, we may need to process your data or share your personal information in the following situations:

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  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
     

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
     

  • Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. See our Cookie Policy: http://www.exate.com/cookie-policy for further information.

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7.4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

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In Short:  We may use cookies and other tracking technologies to collect and store your information.

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We may use cookies and similar tracking technologies to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy: http://www.exate.com/cookie-policy

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7.5. HOW LONG DO WE KEEP YOUR INFORMATION?

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In Short:  We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

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We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 2 years.

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When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

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7.6. DO WE COLLECT INFORMATION FROM MINORS?

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In Short:  We do not knowingly collect data from or market to children under 18 years of age.

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We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please email dpo@exate.com.

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7.7. WHAT ARE YOUR PRIVACY RIGHTS?

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In Short:  In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

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In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided above. We will consider and act upon any request in accordance with applicable data protection laws.

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If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

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If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

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Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/. For further information, please see our Cookie Policy: http://www.exate.com/cookie-policy

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7.8. DO WE MAKE UPDATES TO THIS POLICY?

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In Short:  Yes, we will update this policy as necessary to stay compliant with relevant laws.

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We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

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7.9. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

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Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request by emailing us at dpo@exate.com. We will respond to your request within 30 days.

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8. CHANGES TO THIS PRIVACY NOTICE

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We regularly update our privacy notice to ensure that it is up to date and accurate. This is version 2.0.

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