Privacy Policy - X-Forces Enterprise

PRIVACY POLICY AND DATA PROTECTION

X-Forces Enterprise (XFE) takes the privacy of our beneficiaries, supporters, members and volunteers very seriously.  This policy states how we collect data, how we store it, how we use it and how those who give us their details can request that their data is used by XFE.

1. Who are we and who is responsible for your personal data?

1.1  X-Forces (XF) C.I.C is a social enterprise and private company limited by shares and incorporated in England and Wales.  (Referred to as ‘X-Forces Enterprise’, ‘XFE’, ‘we’, ‘our’, or ‘us’ in this policy)

1.2  Our registered number is 08034041.  Our registered address is 37 Warren Street, London, W1T 6AD. Our Head Office is Mountbarrow House, 6-20 Elizabeth Street, London, SW1W 9RB

1.3  At XFE we are committed to protecting your privacy. This policy describes how XFE collects and uses personal information about people who visit our websites and give us their data over the phone, face to face, and in writing. The terms of this policy may change, so please check it from time to time.

1.4  XFE may appoint certain other service providers to process your personal data on our behalf in connection with the services we provide. If you are applying for a loan your data may be shared with the Start Up Loans Company (“SULCo”) and our finance partner, The Enterprise Fund Limited t/a Business Finance Solutions. If you are applying for a training workshop your data may be shared with our Military Charity partners.

1.5 In some cases, we may also appoint an organisation or individual to provide you with guidance in relation to the services that you will receive from us (“Mentor”). If a Mentor is appointed the Mentor will also process your personal data on our behalf. You may enter into an agreement directly with any such Mentor, however the provisions of this Privacy Policy will also apply to the processing of your personal data by the Mentor.

This policy was last updated and issued on 23rd August 2019.

If you have any queries about this policy please contact:

The Data Protection Officer
X-Forces Enterprise
Mountbarrow House, 6-20 Elizabeth Street
London,
SW1W 9RB

dataprotection@x-forces.com

 

2. How do we collect information?

2.1  We obtain personal information from you when you enquire about our activities, register with us, send or receive an email, ask a question about our services or otherwise provide us with personal information. We may also receive information about you from third parties; for example from our service providers or from a friend who wants to tell you about our websites or the assistance we may be able to provide or the fundraising activities we carry out.  We also collect data when you complete an interest form when responding to any of our paid advertising on social media sites such as but not limited to Facebook and Instagram or when you register for events through our events booking site.

2.2  We may also collect data from third parties, including our finance partners, credit reference agencies and military charities, to make a decision about the payment methods or other arrangements we offer you when receiving a Start Up Loan or receiving training.

 

3. What information do we collect?

3.1  The personal information we collect might include:

  • Your name, date of birth and gender
  • Your ethnicity, qualification levels and employment status
  • Your contact details: postal address, telephone numbers (including business, personal & mobile numbers) and e-mail address
  • Your bank details and existing financial commitments
  • Your device’s IP address
  • Your online browsing activities on the Company website
  • Your communication and marketing preferences
  • Your interests, preferences, feedback and survey responses
  • Your military service number
  • Your location
  • Your correspondence and communications with us

 

We may also collect other personal information such as information about your service or career history if this is required for the purpose you have contacted XFE.

3.2 We also gather general information about the use of our websites, such as which pages users visit most often, and which services, events or facilities are of most interest. We may also track which pages users visit when they click on links in XFE emails. We may use this information to personalise the way our websites are presented when users visit them, to make improvements to our websites and to ensure we provide the best service for users. Wherever possible we use aggregated or anonymous information which does not identify individual visitors to our websites.

3.3  This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this notice. Some of the above personal data is collected directly, for example when you engage with us. Other personal data is collected indirectly, for example your browsing activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources such as credit reference agencies.

Please see the section below on Cookies.

 

4. How do we use this information?

4.1 We will use your personal information for:

  • Dealing with your enquiries and requests and effectively communicating with you
  • Verifying your identity where relevant
  • Contacting you and providing information about products and services that may be useful to you or your business proposition
  • Administering cohort records
  • If you have applied for a Start Up Loan, to assess your eligibility, including assessing lending risks and obtaining a credit reference
  • Providing and personalising our services
  • Administering orders and accounts relating to our suppliers or customers
  • Conducting market research
  • Profiling and segmentation so that we can offer supporters products relevant to them
  • Marketing including any information provided to us in relation to yourself or your business and/or any photos for marketing purposes, including on our website, social media, press releases, printed materials etc.
  • To make our website and other social media content available to you
  • For Administrative purposes
  • As part of this, we may analyse the personal information we collect to create a profile of your interests and preferences so that we can contact you in the most appropriate way and with the most relevant information. Where relevant, we may also assess your personal information for the purposes of fraud and credit risk reduction.
  • If you enter your contact details in one of our online registration forms, we may use this information to contact you even if you don’t “send” or “submit” the form. We will only do this to see if we can help with any problems you might be experiencing with the form or with our websites.
  • We may need to share your information with our service providers, associated organisations and agents for the purposes described above.

Certain types of personal information, such as gender and ethnicity, are used only as part of our contractual reporting requirements, for the purposes of monitoring and promoting equal opportunities.

 

4.2  Where you have received a Start Up Loan we and/or any Mentor, may disclose your personal data to each other and The Start Up Loans Company (‘SULCo’) may:

  • contact you directly for the purposes of monitoring its, our or any Mentor’s performance and/or the Start-Up Loans Programme;
  • use your personal data in case studies for the purposes of advertising and marketing the Start Up Loans Programme;
  • disclose your personal data to its partners, and/or auditors or other advisers auditing any of its business processes;
  • disclose your personal data to the Department for Business, Energy and Industrial Strategy (“BEIS”) and other government departments, bodies, agencies or authorities as required to do so by BEIS or other government departments, bodies, agencies or authorities;

and disclose your personal information to third parties if it is under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or in order to enforce or apply these terms or its or our or any Mentor or partner’s separate terms and conditions of supply or other agreements; or to protect the rights, property, or safety of SULCo, us or any Mentor or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction or law enforcement or the administration of justice.

 

5. How long do we keep your information for?

How long we keep your information will depend on the purpose for which we use it. We will only retain your information for as long as is necessary for those purposes.

 

6. Your choices

You have a choice about whether you want to receive information about our progress and marketing activities. We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted. You can change your marketing preferences (such as email or post at any time), by contacting:

X-Forces Enterprise
Mountbarrow House, 6-20 Elizabeth Street
London,
SW1W 9RB

Tel: 0800 368 9533

E-mail: info@x-forces.com

 

7. X-Forces Enterprise Privacy Statement

The EU General Data Protection Regulation (GDPR) provides the legal framework on how personal information can be used and protected. XFE is fully committed to complying with this regulation and has a legal duty to protect any information we collect from you.

  • Your personal information is only used for the purpose for which we collect it
  • Only information that we actually need is collected
  • Your personal information is only seen by those who need it to do their jobs
  • We will not pass your personal information on to any other organisation without your consent unless we are required to do so by law (see “How do we use this Information?” above)
  • Personal information is retained only for as long as it is required for the purpose collected
  • We will, where necessary, keep your information up to date
  • Your information will be protected from unauthorised or accidental disclosure
  • We will provide you with a copy of your personal information on request (please see below for information on access rights and requests)
  • Inaccurate or misleading data will be corrected as soon as possible

These principles apply whether we hold your information on paper or in electronic form.

 

8. Access Rights and Requests

You have the right to see what personal data we hold about you. Subject access requests must be submitted in writing.  To obtain a copy of the personal information we hold about you, please write to us or submit your form to:

X-Forces Enterprise
Mountbarrow House, 6-20 Elizabeth Street
London,
SW1W 9RB

E-mail: dataprotection@x-forces.com

 

9. Transfer of Information Outside of the EU

Given that the Internet is a global environment, using it to collect and process personal data necessarily involves the transmission of data on an international basis. This means for instance that data you pass to us may be processed outside the European Economic Area, although the data will always be held securely and we will take steps to ensure they provide an adequate level of protection in accordance with the UK’s Data Protection Act. By submitting your personal information you agree to this transfer, storing or processing at a location outside the EEA.

 

10. Right to prevent processing of your personal data

10.1  You have a right to object to XFE processing your personal information if it is likely to cause or is causing you damage or distress. Such a request would have to be made in writing and you must set out why the processing is having this effect.

10.2  This can be sent to the Data Protection Officer at the postal address or e-mail address provided above.

 

11. How do we protect personal information?

All of our online forms are protected by encryption. We take appropriate measures to ensure that the personal information disclosed to us is kept secure, accurate, and up to date.  We will ensure that your personal information is kept only for so long as is necessary for the purposes for which it was collected and is securely destroyed in accordance with our data retention and disposal policy.

 

12. Will we disclose the information we collect to outside parties?

12.1  We do not share or sell details to charities or other third parties.

12.2  In providing our services to you, on behalf of our partners, we will only share the personal data that is required to deliver the services to you.

12.3  We will only disclose data when obliged to disclose personal data by law, or the disclosure is ‘necessary’ for purposes of national security, taxation and criminal investigation, or we have your consent, and to the following:

  • Suppliers we engage to process data on our behalf. In such cases information is only shared for the purpose of providing services on our behalf relating to communications, or agreements between yourself and XFE. Such processing is conducted under relevant Data Processing Agreements.

We will not sell any information about your web browsing activity.

 

13. Cookie Usage

A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. Cookies help us to provide you with a better experience by allowing us to understand what areas of the website are of interest to our visitors (e.g. via Google analytics).

Our cookies aren’t used to identify you personally. They collect anonymous information on the pages visited and we do not use advertising cookies. Most browsers will allow you to turn off cookies. Please note however that turning off cookies will restrict your use of our website. To learn more about cookies and how to manage them, visit AboutCookies.org.

 

14. Trademarks and copyright

Group websites contains material which is protected by copyright and/or other intellectual property rights. All copyright and intellectual property rights including the names, images and logos are owned by X-Forces unless otherwise stated. All rights are reserved.

You are responsible for complying with all applicable copyright laws. We permit you to make copies of information on reasonable for private purposes. All other uses are prohibited. Nothing in these terms shall be construed as conferring any right to use any trademark, logo, patent right or copyright of XFE.

 

15. Your consent

By providing us with your personal information, including sensitive information such as medical details, you consent to the collection and use of this in accordance with the purposes described in this policy.

 

16. Links

Our websites may include links to websites run by other organisations. XFE is not responsible for the privacy practices of these other websites so you should read their privacy policies carefully.

 

17. Changes

If your personal details change, please help us to keep your information up to date by notifying the relevant department.

If you are supporter and wish to update us with your information please contact us at the address below:

X-Forces Enterprise
Mountbarrow House, 6-20 Elizabeth Street
London,
SW1W 9RB

We may change the terms of this privacy statement from time to time. If we do so, we will post the changes here so please check from time to time. By continuing to use our websites you will be deemed to have accepted such changes.

 

18. Data Protection Regulator

Further information and advice about data protection is available from:

The Office of the Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Tel: +44 (0) 01625 545 745

Website: www.ico.org.uk