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Cookie Policy & Privacy Policy


This policy sets out how Xara Computers (UK) Ltd (XC360) uses cookies on xc360.co.uk and how we protect any personal information you give to XC360 when using this website.  We are committed to ensuring that your privacy is protected and the use of cookies is made transparent to you. This policy applies where we are acting as the data controller with respect to the personal information you provide through using this website and how we process that personal information.

XC360 may change this policy from time to time by updating this page. You should check this page occasionally to ensure that you are happy with any changes. We may notify you of changes to this policy by email. This policy is effective from March 28th 2018.

1.  Cookies

1.1          XC360.co.uk uses cookies – these are small text files that are placed on your machine to help the site provide a better user experience, determine whether you are logged in and provide security, personalise your browsing experience and help us analyse the performance of our website.
1.2          In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
1.3          Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
1.4          Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
1.5          As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.
1.6          Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you may not be able to use all the features on our website.
1.7          Consent of our use of cookies will be requested on first visit xc360.co.uk or you will consent by using this this website and agreeing to this policy.

2.  Privacy
2.1          This is the Privacy Notice of Xara Computers (UK) Ltd as well as our global subsidiaries, (“XC360”), whose head office is located at 2nd Floor Kajaine House, 57-67 High Street, HA8 7DD.

2.2          XC360 develops and maintains windows based cloud platforms and provides technology services (IT Support, Business Continuity, Office365, Backup and Hosted Telecoms and associated technology services) that are designed to help Businesses successfully build, manage and grow their businesses in an efficient and secure manner (collectively “Services”).
2.3          XC360 respects your privacy. This Privacy Notice sets out how XC360 collects and processes your personal data when you access and use our Services, including the site www.xc360.co.uk (“Site”). This Privacy Notice also provides certain information that is legally required and lists certain rights in relation to your personal data under applicable law.

Personal Data
3.1          This Privacy Notice relates to data about you and your interaction with our Services. “Personal Data” is information that can be used to identify you, directly or indirectly, alone, or together with other information. Personal Data includes such things as your full name, email address, phone number, precise location, device IDs, and certain cookie and network identifiers. XC360 collects, uses, and discloses Personal Data as outlined in this Privacy Policy, including to operate and improve the Services and our business; for advertising and marketing; and to provide you products and the Services.

How We Collect Personal Data
3.2          When you contract us for any service or interact with or utilise our Products or Services. We collect Personal Data when you use or interact with our Site and Services, including when you contract with us or browse our products and services online. This Personal Data may include name, address, phone number, username and password, email address, date of birth and location data.

3.3 When you communicate with us on our Support or Accounts telephone numbers we record calls as standard in order to use this for authority for actions we carry out on behalf of our customers as part of our contractual obligations to provide secure IT services.
3.4          When you communicate with us or sign up for promotional materials or newsletters. We collect Personal Data when you communicate with us or sign up to receive promotional materials or information, including email address and phone number and name. 

3.5          When we collect data from third parties or publicly-available sources. We may obtain certain data about you from third-party sources to help us provide and improve the Services and for marketing and advertising. We may combine your Personal Data with data we obtain from our Services, other users, or third parties to enhance your experience and improve the Services.

3.6          When we leverage and/or collect cookies, device IDs, Location, data from the environment, and other tracking technologies. We may collect certain Personal Data using cookies and other technologies, such as web beacons, device IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalisation, performance/analytics, and advertising.

3.7 When you visit our offices, personal data is collected by way of video surveillance. Video surveillance is in place to protect both our visitors and our employees safety.
3.8          Users Under 18 Years of Age. We do not knowingly collect Personal Data online from individuals under 18 years without parental consent. If you become aware that an individual under 18 years of age has provided us with Personal Data without parental consent, please contact us at privacy@xc360.co.uk. If we become aware that an individual under 18 has provided us with Personal Data without parental consent, we will take steps to remove the data as permitted by law.

How We Disclose Personal Data
3.9          We may disclose your Personal Data as described in this Privacy Notice, including:

·            To Affiliates, Partners and Contractors – With companies or ventures that are owned or controlled by XC360 (UK, Russia, Kenya), and internally within XC360, in order to provide and improve Services, for marketing purposes, for advertising, and for analytics.
·            To Service Providers and Vendors – With business partners, marketing partners, and vendors to provide, improve, and personalize the Services.
·            For Advertising and Marketing – With advertising and marketing partners for advertising and marketing purposes on XC360’s behalf and on behalf of third parties.
·            For Certain Analytics and Improvement – With certain companies for purposes of analytics and improvement of the Services.
·            For Interest-Based Advertising – With companies involved in interest-based advertising. This advertising consists of XC360 [and third-party ads] that are personalized and displayed on our sites and through other channels. For more information on how data is disclosed for advertising see Advertising and Analytics section of this Privacy Notice.
·            For Legal Compliance, Law Enforcement, and Public Safety Purposes – As permitted by law, with law enforcement, government or regulatory bodies, lawful authorities, or other authorised third parties in order to comply with laws, regulators, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Privacy Notice, or agreements with third parties, or for crime-prevention purposes.

·            Actual or Contemplated Sale, Acquisition, or Reorganization – In connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, acquisition or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction.

Legal Basis For Processing
4.1          We collect and process your personal data for a variety of different purposes which are set out in further detail below.
In some cases, we will ask for your consent so that we may process your Personal Data. However, in certain circumstances, applicable data protection laws allow us to process your Personal Data without needing to obtain your consent.

Processing Personal Data Where Consent Not Obtained
4.2          In certain cases, separate consent is not required, including:
·            For the performance of a contract. To perform our contractual obligations to you, including our fulfilling orders or purchases you have made, contacting you in relation to any issues with your order or use of the Services, in relation to the provision of the Services, or where we need to provide your Personal Data to our service providers related to the provision of the Services.
·            To comply with legal obligations. To comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process.
·            Legitimate Interests. To operate our business and provide the Services, other than in performing our contractual obligations to you for XC360’s “legitimate interests” for the purposes of applicable law, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Legitimate interests may include:
·            To communicate with you regarding the Services, including to provide you important notices regarding changes to our Terms and to address and respond to your requests, inquiries, and complaints.
·            To send you surveys and reports in connection with our Services.
·            To assist in the investigation of suspected illegal or wrongful activity, and to protect and defend our rights and property, or the rights or safety of third parties.
·            To develop, provide, and improve our Services.
·            To enforce our Terms of Use or this Privacy Notice, or agreements with third parties.

Matters That May Require Consent
4.3          In cases where we are not already authorized to process the Personal Data under applicable law, we may ask for your consent to process your Personal Data, including:
·            Marketing – We may ask for your consent to contact you by telephone, SMS, post and/or email about other offers, products, promotions, developments or services which we think may be of interest to you and for other marketing purposes.
·            Research – We may ask for your consent to use your Personal Data for research purposes.
·            Use of Cookies – The Site uses cookies to improve user experience. (see section 1 Cookie Policy)

Withdrawing Your Consent
4.4          You may at any time withdraw the consent you provide for the processing of your Personal Data for the purposes set forth in this Privacy Notice by contacting us at privacy@xc360.co.uk provided that we are not required by applicable law or professional standards to retain such information.
4.5          If you want to stop receiving future marketing messages and materials, you can do so by clicking the “unsubscribe” link included in our email marketing messages.

De-Identified Or Anonymized Data
5.1          We may create de-identified or anonymous data from Personal Data by excluding data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through obfuscation or through other means. Our use of anonymized data is not restricted by this Privacy Notice.

Data Retention
6.1          We will retain your Personal Data for as long as long as you maintain an account or as otherwise necessary to provide you the Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

6.2          Where we no longer need to process your Personal Data for the purposes set out in this Privacy Notice, we will delete your Personal Data from our systems.
6.3          Where permissible, we will also delete your Personal Data upon your request, as further described in the Data Subject Access, Modification, and Deletion Rights section of this Privacy Notice.

Advertising & Analytics
7.1          Interest-based advertising is advertising that is targeted to you based on your web browsing and app usage over time. We disclose various types of de-identified information to enable interest-based advertising. You have the option to restrict the use of information for interest-based advertising and to opt-out of receiving interest-based ads.

7.2          You can make decisions about your privacy and the ads you receive. You can control whether companies serve you on-line behavioural advertising by visiting the Digital Advertising Alliance website and using its opt-out: http://www.youronlinechoices.com/ (EU). The DAA opt-out requires that cookies not be blocked in your browser.
7.3          As an alternative to the DAA opt–out, you can also elect to block browser cookies from first parties (such as those from our website) and browser cookies from third parties (such as advertisers) by using the cookie blocking options built into your browser software. If you block browser cookies, some parts of our website may not function correctly. Also, blocking cookies will not stop third-parties from collecting IP address, data stored in “Flash” cookies, and certain other types of technical information that may uniquely identify your browser.
7.4          Due to the lack of consensus around a Do Not Track standard, our websites to not change how they collect or track data when they receive the “Do Not Track” flag.

Social Network Widgets
8.1          Our Site may include social network sharing widgets that may provide information to their associated social networks or third-parties about your interactions with our web pages that you visit, even if you do not click on or otherwise interact with the plug-in or widget. Information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where widget appears. If you use social network tools or visit social networking sites, you should read their privacy disclosures, to learn what information they collect, use, and share.

Why We Collect And Process Your Personal Data
9.1          We need to process certain Personal Data in order to fulfil our contractual obligations to you and to provide you with the Services.

9.2          Where we ask for your consent to process your Personal Data, you have the right to withdraw such consent as described in this Privacy Notice. Please note, however, we may be unable to provide you certain Services that require the use of Personal Data.
9.3          Please note that even where your consent would otherwise be required, we may nevertheless process your Personal Data in accordance with our legitimate interests under applicable law, as described in this Privacy Notice.

Transfer And Storage Of Personal Data
10.1 XC360 and associated Services and systems will only be stored on servers within the EU and primarily in the United Kingdom. Our partners / contractors based in Russia and Kenya will have access to these Servers from time to time to fulfil contractual obligations, however our agreements and security mechanisms restrict them from physically transferring this data outside of the EU and using this data for anything other than their service obligations.
10.2 Personal Data may, from time to time, be transferred to contractors in a third country (Kenya and Russia) after appropriate data protection measures have been taken and agreements to comply with UK data protection legislation enforced. Access to personal Data by these contractors will only be provided via secured remote connection to our systems with multi-factor authentication. This data will only be provided in order to meet our contractual obligations with our customers. All data will be encrypted and inaccessible from external sources. Auditing and monitoring of personal data access is implemented as standard.
10.3 By using our Services and/or submitting your Personal Data, you agree to the transfer, storage, and/or processing of your Personal Data as described in this privacy notice.

Data Subject Access, Modification, And Deletion Rights
11.1        You have the right in certain circumstances to request confirmation from us as to whether or not we are processing your Personal Data. Where we are processing your Personal Data, you also have the right to request access to, modification of, or deletion of such Personal Data.

11.2        You have the right in certain circumstances to receive the Personal Data concerning you that you provided to us and have the right in certain circumstances to transmit such data to another controller.
11.3        To exercise your rights with respect to your Personal Data, please contact us at privacy@xc360.co.uk. As permitted by law, certain data elements may not be subject to access, modification, and/or deletion. Furthermore, we may charge for this service and will respond to reasonable requests as soon as practicable and as required by law.

Right To Lodge A Complaint With A Supervisory Authority
12.1        You may have a right to lodge a complaint with a supervisory authority. (for further guidance see here: https://ico.org.uk/concerns).

Security Safeguards And Links To Other Websites 
13.1        We implement appropriate technical and organizational safeguards to protect against unauthorized or unlawful processing of Personal Data and against the accidental loss, destruction, or damage of Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.

13.2        This Privacy Notice only applies to our Site and Services. Our Site or Services may provide a link or otherwise provide access to another website, mobile application, or Internet location (collectively “Third-Party Sites”). We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Policy does not apply to Third-Party Sites, and any data you provide to Third-Party Sites, you provide at your own risk. We encourage you to review the privacy policies of any Third-Party Sites with which you choose to interact.

Contact Us
This website is owned and operated by Xara Computers (UK) Ltd (“XC360”). We are registered In England and Wales at 24 Bedford Row, WC1R 4TQ with Company No: 04012870 and VAT No: 757 148 408. Our principal place of business is at Second Floor, Kajaine House, 57-67 High Street HA8 7DD. You can contact us on the above address or by using our website contact form or on any of the contact email addresses and phone numbers published on this site. For questions regarding this Privacy Notice, please contact us at: privacy@xc360.co.uk.