1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, "we", "us" and "our" refer to Xeio Ltd, a company registered in England and Wales company number 8134729, trading as Localnumberize!.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use including phone numbers and phone numbers of customers who call any forwarding numbers you establish using our service. This data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your user account data ("account data"). The account data may include your business details, name and email address. The source of the account data is you and Shopify. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us to provision our services.
2.4 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is the performance of a contract between you and us to answer your questions and provision our services.
2.5 We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, and the transaction details. The source of the transaction data is you and Shopify. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; providing that, if you are not the person contracting with us, the legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent, which may be changed at any time.
2.7 We may process information associated with communications, including calls to forwarding numbers we may establish ("communication data"). The communication data may include the communication metadata associated with the communication – for example, the number of the caller and their country. The communication data may be processed to deliver our service. The legal basis for this processing is the performance of a contract between you and us to provision our services.
2.8 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.9 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, ensuring compliance according to any government or regulator, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. Providing your personal data to others
3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 Your personal data held in our databases will be stored on the servers of our hosting services provider, Google Ireland Limited with offices at Gordon House, Barrow Street, Dublin 4, Ireland: https://cloud.google.com/
3.4 Personal data about you and customers who call forwarding numbers may be accessible by our supplier Twilio Inc, insofar as reasonably necessary for service provision. You can find information about this service provider’s privacy policies and practices at https://www.twilio.com/legal/privacy
3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 We have offices in the United Kingdom, and the hosting facilities for our website and underlying databases are situated in the United Kingdom.
4.3 Our supplier Twilio Inc, who provision telecommunication services for our users and act on our behalf as a Data Processor, uses servers based in the United States. Any transfer of data to the United States will be protected by appropriate safeguards, namely the use of binding corporate rules, a copy of which you can obtain from https://www.twilio.com/legal/bcr/processor
4.4 Our supplier Cloudflare Inc, who provision reverse proxy and security services for our users and act on our behalf as a Data Processor, uses servers based in the United States. Any transfer of data to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://www.cloudflare.com/media/pdf/cloudflare-customer-dpa.pdf
4.5 You acknowledge that personal data that you submit through our website or gathered in the provision of our services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) usage data will be retained for a minimum period of 30 days following the date of collection, and for a maximum period of 1 year following that date;
(b) account data will be retained for a minimum period of 24 hours following the date of closure of the relevant account, and for a maximum period of 72 hours following that date;
(c) enquiry data will be retained for a minimum period of 24 hours following the date of the enquiry, and for a maximum period of 1 year following that date;
(d) transaction data will be retained for a minimum period of 24 hours following the date of the transaction, and for a maximum period of 1 year following that date;
(e) notification data will be retained for a minimum period of 24 hours following the date that we are instructed to cease sending the notifications, and for a maximum period of 1 year following that date (providing that we will retain notification data insofar as necessary to fulfil any request you make to actively suppress notifications);
(f) communication data will be retained for a minimum period of 24 hours following the date of the communication in question, and for a maximum period of 1 year following that date
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of data will be determined based on our determination of the likelihood of needs to reference that data in future, for example to answer customer questions of the provision of prior service
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Security of personal data
6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
6.2 We will store any personal data on secure servers, personal computers and mobile devices.
6.3 Data relating to your enquiries and service transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
6.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
6.6 You should ensure that your overall Shopify account is kept secure and that your Shopify password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for maintaining the integrity of the Shopify account you use for accessing our services, and are aware that its access by third parties could diminish your data security and/or could incur costs on your behalf via use of our services.
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask use to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by emailing [email protected]
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by contacting us via email on [email protected]
8. Third party websites
8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
9. Personal data of children
9.1 Our website and services are targeted at persons over the age of 18.
9.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 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.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use
13. Cookies used by our service providers
14. Managing cookies
14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
14.2 Blocking all cookies will have a negative impact upon the usability of many websites.
14.3 If you block cookies, you will not be able to use all the features on our website and service.
15.1 We may update this policy from time to time by publishing a new version on our website.
15.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
16. Our details
16.1 This website and service is owned and operated by Xeio Ltd.
16.2 We are registered in England and Wales under registration number 8134729 and our registered office is at First Floor, Telecom House, 125-135 Preston Road, Brighton, East Sussex, BN1 6AF, United Kingdom.
16.3 Our principal place of business is at 86-90 Paul Street, 3rd Floor, London EC2A 4NE, United Kingdom.
16.4 You can contact us:
(a) by post, to the postal address given above;
(b) by email, to [email protected]
17. Data protection registration
17.1 We (Xeio Ltd) are registered as a data controller with the UK Information Commissioner's Office.
17.2 Our data protection registration number is Z3404574.
Last Update: 17th May 2019