Privacy & Cookies Policy

As the operators of the website www.xceptor.com (“Website”), Xceptor ("We", “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

 

For the purpose of the General Data Protection Regulation (“GDPR”, from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the “Data Protection Laws”) the Data Controller is Web Services Integration Limited, 85 Gresham Street, London EC2V 7NQ.

 

YOUR PERSONAL INFORMATION

 

Information we collect from you

 

We collect and process some or all of the following types of information from you in the course of your use of the website and/or us providing our services to you:

 

• Information that you provide for example by filling in forms on the Website; filing in forms as part of the registration process; completing information for training purposes. This includes information provided at e.g. the time of registering to use the Website, subscribing to our mailing list, or requesting any further information or services. We may also ask you for information if you report a problem with the Website; contact our HelpDesk; or contact us for training purposes.

 

• Specifically, personal details such as name, job title, department of work, name and address of business you work for/with, email address, date of birth, country of residence or any information input by when using the Website, completing our survey forms, using our Services.

 

• In addition to the above and with regard to our Learning Management System , we will collect and record data related to course participation such as course registrations, attendance, course completions, assessment and feedback.

 

• If you contact Us, We may keep a record of that correspondence.

 

• We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.

 

• Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.

 

• Information that you disclose to any of our employees (such as date of birth, favourite football team, number of children, food/drink preferences) solely for the purpose of allowing Us to develop a more personal relationship with our customers.

 

The provision of name, email address, business address and contact telephone number is required from you to enable Us to consider licensing any software to you or providing any of our services. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us

 

Information We Collect From Other Sources

 

We will also obtain personal data from other sources as follows:

• Contact details from third party event organisers which will be private businesses but which may be situate anywhere in the world. Such information may be held by us and our Affiliate businesses or by third party data processors on our behalf.

 

USES MADE OF YOUR INFORMATION

 

Lawful basis for processing

 

We rely on your consent when you sign up to our website; or our contractual obligations if we are in a contractual relationship with you or your employer; or in order to fulfil our legal obligations under a third party contract which you are aware of as the lawful basis on which We collect and use your personal data.

 

If we are in a contractual relationship with you or your employer we have a legitimate interest in maintaining up to date personal contact information to enable us to meet our contractual obligations.

 

Purposes of processing

 

We use information held about you in the following ways:

 

• To provide you with our services.

 

• To analyse training and usage of our LMS, where applicable.

 

• To notify you about new or improved training.

 

• To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website;

 

• To provide you with information that you request from Us or which We feel may interest you.

 

• To carry out our obligations arising from any contracts entered into between you and Us.

 

• To allow you to participate in interactive features of our service, when you choose to do so.

 

• To notify you about changes to our service.

 

• We will never share your information with any third party for any purposes other than the continued marketing (including without limited by means of newsletter, emails, blogs, events etc) of our products and/or services to you and/or the organisation you work for.

 

 

Marketing

 

In addition to the above uses We may use your information (and, where you have consented, permit selected third parties to use your information), to notify you about goods or services which may be of interest to you. Where We do this, We will contact you by electronic means (e-mail or SMS) only if you have consented to such communication.  If you do not want Us to use your data in this way please either (i) tick the relevant box situated on the form on which We collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform Us at any time by contacting Us at the contact details set out below.

 

Automated decision making/profiling

 

Within our LMS we have an auto-enrol feature which means that you may be automatically assigned to additional training based on your previous choices.  We will be placing individuals into groups based on criteria which will be determined from the information you have provided to us.

 

We may also request you to complete an online survey which we may use to further tailor our marketing.

 

DISCLOSURE OF YOUR INFORMATION

 

We routinely disclose your personal data to third parties as follows:

 

• We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf.

 

• We may do so for the purposes of telemarketing; outsourcing of marketing function; the outsourcing of the despatch of corporate gifts; and in the event of any problems or queries with our LMS.

 

We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

 

We may also disclose your personal data to third parties:

 

• in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or

 

• if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or

 

• if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our:

 

1. Website Terms and Conditions;
2. LMS Terms and Conditions;
3. Any obligations within any contracts with you/your employer or any third party.

 

• to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with to provide the Website; or

 

• in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be of interest to you.

 

Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.

 

STORING YOUR PERSONAL DATA

 

Security

 

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way.   We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

 

Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Website or our LMS, you are responsible for keeping this password confidential.

 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security 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 the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

 

Keeping your personal data up to date

 

If your personal details change you may update them by accessing the relevant page of the Website/Learning Management System, or by contacting Us using the contact details belowIf you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.

 

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.

 

How long we keep your personal data

 

• We will hold the personal details we have obtained from you for as long as: we are in a contractual relationship with you/your employer and the period of time thereafter that we are bound by any continuing obligations; or We are required to retain this information by applicable UK tax law.

 

Where we store your personal data

 

All information We hold about you is stored on secure servers.

 

The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

 

Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that all countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to relevant safeguards (as permitted under Article 46(5) of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

 

If you would like further information please contact Us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom OR EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

YOUR RIGHTS

 

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• access to your personal data and to certain other supplementary information that this Policy is already designed to address
• require Us to correct any mistakes in your information which We hold
• require the erasure of personal data concerning you in certain situations
• receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal data concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal data
• otherwise restrict our processing of your personal data in certain circumstances
• claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

 

If you would like to exercise any of those rights, please:

• email, call or write to Us
• let Us have enough information to identify you,
• let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let Us know the information to which your request relates.

 

HOW TO COMPLAIN

 

We hope that We can resolve any query or concern you raise about our use of your information. Please see Contact details below for further assistance.

 

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

CHANGES TO OUR PRIVACY POLICY

 

We reserve the right to modify this Policy at any time. Any changes We may make to our Policy in the future will be notified and made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied privacy policy.

INFORMATION ABOUT OUR USE OF COOKIES AND IP ADDRESSES

 

We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users’ browsing actions and patterns,and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services. 

 

Our Website uses cookies to distinguish you from other users of our Website. This helps Us to provide you with a good experience when you browse our Website and also allows Us to improve the Website. By using our Website you agree to our use of cookies as more specifically set out below.

 

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.

 

The cookies We use include:

 

• “Analytical” They allow Us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps Us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

• “Strictly necessary” cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
• “Functionality” cookies. These are used to recognise you when you return to our Website. This enables Us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• “Targeting” cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed to our affiliates websites. We will use this information to make our Website, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third party affiliates may also use cookies, over which We have no control.

 

You may 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 Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website.

CONTACT

 

Any requests to remove your data or update your information should be addressed to either:

 

helpdesk@xceptor.com where you need to update details and are receiving Support services from Us;

hello@xceptor.com where you are receiving marketing materials from Us; or

julie.woodward@xceptor.com where you wish to update your LMS details.

 

All other questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to juliet.nutland@xceptor.com; or write to Us at For the attention of the Legal Department, 85 Gresham Street, London EC2V 7NQ