IQX Privacy Policy [iqx]

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====== IQX Privacy Policy ======

=====1 - Introduction=====

This privacy policy ( **Policy** ) relates to your personal information in connection with your use of and access to any IQX website including our main website (iqx.co.uk), our Support Website (iqxusers.co.uk), any IQXanywhere website (IQXanywhere.co.uk - the **IQXanywhere Platform** ) or any other service however provided by IQX Limited.

We are committed to protecting your information and your right to privacy. If you have any questions or concerns about our Policy, or our practices with regards to your personal information, please contact us via info@iqx.co.uk.

When you use an IQX service, you trust us with your information and we take your privacy very seriously. 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 Policy that you do not agree with, please discontinue your use of the IQX service.

In this Policy, any reference to “Terms” means any terms, conditions, agreements, contracts or policies that govern or apply to your relationship with us.
=====2 - Changes to this Policy or your personal information=====

We review this Policy regularly and it is your responsibility to check regularly and determine whether you still agree to comply with the Policy. If you do not agree to any changes to this Policy then you must immediately stop using an IQX Service. In the event we make any significant changes to this Policy we will use our reasonable endeavours to inform you of such changes in advance in writing.

It is important that the personal information we hold about you is true, complete, accurate and current. Accordingly, you must notify us of any changes to your personal information (for example, if you change your email address).

=====3 - About us=====

This Privacy Policy applies to all products, applications and services offered by  IQX Limited (trading as "IQX"), a company registered in Scotland with company number SC171786 and whose registered office is situated at Wester Newhouse Lilliesleaf, Melrose, Roxburghshire, TD6 9JT ( **IQX/we/us/our** ). IQX is the controller (also known as a data controller) of, and is responsible for, your personal information. The term "you" refers to the user wishing to access and/or use an IQX Service.

=====4 - Information we may collect about you=====
===4.1 - Personal information you disclose to us===

**In Short: We collect personal information that you provide to us including information such as your name, address, contact information, employer, job title, date of birth and payment information**

We collect personal information that you voluntarily provide to us when registering to use and actually using an IQX Service, or otherwise contacting us.

If you apply for a job with us, or work for us for any period of time, we also collect your personal information, which may include your contact details, financial and payment details, details of your education, qualifications and skills, your marital status, your nationality, your NI number, your job title and your CV.

If you give us information on behalf of another individual, for example when putting that individual forward as your emergency/alternate contact or referee or next of kin, or by acting as that individual's emergency/alternate contact, referee or next of kin, in providing that information to us you are confirming that you have sought and obtained, from that individual, permission for you to:
  * Consent on their behalf to the processing of their personal data;
  * Receive on their behalf any data protection notices; and
  * If relevant, consent to the transfer of their personal data abroad,
and you shall indemnify and hold harmless IQX against any claims, actions, proceedings, losses, damages, costs (including reasonable legal costs) and expenses (including taxation), in each case of any nature whatsoever, arising out of or in connection with your failure to obtain these permissions.

More particularly, the personal information that we collect depends on the context of your interactions with us, the choices you make and the products and features you use.
  * We gather information directly from you face to face if you come to our offices for information or to sign a licence agreement and over the telephone if you ring us to make an enquiry.
  * We collect personal information via our website, mobile applications and other technical systems.
  * We collect personal information when you use our website or mobile applications to sign up to, participate in or receive a service from us, such as requesting a quote online or entering a live chat.
  * Our website also uses cookies and collects IP addresses (for more information on this, see our [[https://iqx.co.uk/legal/cookies/|Cookie Policy]] ). We also collect personal information when you contact us or send us feedback.
  * We may monitor and record communications with you (such as telephone conversations and emails). We may do this for a number of reasons, such as to check the quality of our customer service, for training purposes, to prevent fraud or to make sure we are complying with legal requirements.
  * If you visit our offices, some personal data may also be collected from monitoring devices and systems such as closed-circuit TV (CCTV).

When you use an IQX Service and/or when you otherwise deal with us as set out above, we may collect the following information about you (the **Information**):
  * **Identity Data** , which includes your first name, last name, information about your employment and gender.
  * **Contact Data** , which means the data we use to contact you including your billing address, delivery address, email address and contact number.
  * **Financial Data** , which means the payment method and any card association used to process your payments for your orders. We do not store or process your card or bank account details ourselves, they are processed and stored via one of our contracted third-party service providers. We encrypt your payment card or bank account details in your browser and securely transfer this data to our relevant third-party payment provider to process a payment.
  * **Transaction Data** , which means details about transactions you have made in connection with an IQX Service, including the payments to and from you along with other details of products you have purchased from us.
  * **Profile Data** , which includes your username, email address and log-in data, details of any purchases or orders made by you, your interests, preferences, feedback and survey or questionnaire responses and details of your next of kin, emergency/alternate contact(s) or referee(s) (note: you can delete or replace your next of kin, emergency/alternate contact(s) or referee(s) at any time by contacting us using the information set out in section 16 below).
  * **Usage Data** , which includes Information about how you use an IQX Service. This includes your browsing patterns and Information such as how long you might spend on one of our webpages, what you look at and for, the page that referred you to that IQX service and the click stream during your visit to our website, page response times, and page interaction Information (for example, clicks you make on a page).
  * **Marketing and Communications Data** , which includes your preferences with regards to receiving marketing from us and your other communication preferences.
  * **Other Information relevant to services, customer surveys, questionnaires and/or offers**.

===4.2 - Sensitive personal information===

**In Short: Occasionally we may need to ask you to provide sensitive personal data. If we do, we will explain why we are requesting it and how we will use it.**

We will not usually ask you to provide sensitive personal information. We will only ask you to provide sensitive personal information if we need to for a specific reason, for example, if we believe you are having difficulty dealing with your account due to illness. If we request such information, we will explain why we are requesting it and how we will use it.

Sensitive personal information includes information relating to your ethnic origin, political opinions, religious beliefs, whether you belong to a trade union, your physical or mental health or condition, sexual life, and whether you have committed a criminal offence. We will only collect your sensitive personal information with your explicit consent.

===4.3 - Personal information from third parties===

**In Short: We may receive information about you from third parties, and we may use this information to provide, improve and personalise an IQX Service.**

Occasionally we may receive information about you from other sources (such as credit reference agencies), which we will add to the information we already hold about you in order to help us provide, improve and personalise an IQX Service. If you apply for a job with us, we may also receive information from those who provide references relating to your prospective or actual employment.

===4.4 - Information automatically collected===

**In Short: Some Information – such as IP addresses and/or browser and device characteristics – is collected automatically when you use an IQX service.**

We automatically collect certain Information when you visit, use or navigate an IQX service. This Information does not reveal your specific identity (unless your device name is the same as your name) 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 the IQX Service and other technical Information. This Information is primarily needed to maintain the security and operation of the IQX Service, and for our internal analytics and reporting purposes.

Like many businesses, we also collect Information through cookies and similar technologies. You can find out more about this in our [[https://iqx.co.uk/legal/cookies/|Cookie Policy]].

=====5 - How do we use your Information?=====

**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**

We use your Information collected via the IQX Services for a variety of business purposes described below. We process your Information for these purposes in reliance on our legitimate business interests ( **Business Purposes** ), in order to enter into or perform a contract with you ( **Contractual Reasons** ), with your consent ( **Consent** ), and/or for compliance with our legal obligations ( **Legal Reasons** ). We indicate the specific processing grounds we rely on next to each purpose listed below.

We may process your Information for the following purposes:

  * To take steps towards entering into a contract with you, to provide a service and to claim any right to be paid under our Terms (Contractual Reasons). This includes collecting and using your personal information to:
    * enable us to follow up on enquiries made by you in relation to our software in accordance with industry guidelines and to give you our quote;
    * run a credit check against you, to enable us to make credit decisions about you (and the people or businesses associated with you) and to help prevent and detect fraud and money laundering. Our search will be recorded on the files of the credit reference agency. We may also disclose information about how you conduct your account to credit reference agencies and your information may be linked to records relating to other people living at the same address or who are financially linked to you. Other credit businesses may use your information to make credit decisions about you and the people with whom you are financially associated, trace debtors, and prevent and detect fraud and money laundering. If you provide false or inaccurate information to us and we suspect fraud, we will record this;
    * prepare a licence or services agreement with you;
    * manage any accounts you hold with us;
    * contact you for reasons related to an IQX Service you have signed up for or to provide the information you have requested;
    * contact your next of kin or your emergency/alternate contact(s) in order to get in touch with you when we have failed to do so using your own contact details
    * contact your referee(s) or to obtain a reference for a job that you are applying for;
    * deal with payment for an IQX Service;
    * notify you of any changes to our Site or to an IQX Service that may affect you; and
    * resolve disputes or collect overdue payments.
  * To pass onto our brand partners to fulfil and manage your orders, payments, returns, and exchanges.
  * To facilitate a recruitment process in which you are involved.
  * To follow up on enquiries in accordance with industry guidelines and providing quotes for software/details of offers (Business Purposes).
  * To send administrative Information to you for Business Purposes, Legal Reasons and/or possibly Contractual Reasons. We may use your Information to send you product, service and new feature Information and/or Information about changes to our Terms and policies.
  * To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our brand partners may use your Information for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails (see below for further details).
  * To facilitate account creation and log-in processes with your Consent. If you choose to link your account with us to a third party account (such as your Google or Microsoft account), we use the Information we are consequently allowed to collect from those third parties to facilitate account creation and the log-in process. See the section below headed "How Do We Handle Your Social Media Log-ins" for further information.
  * To administer promotions for our Business Purposes and/or with your Consent.
  * To request Feedback for our Business Purposes and/or with your Consent. For example, we may use your Information to request feedback and to contact you about your use of a Service.
  * To protect an IQX Service for Business Purposes and/or Legal Reasons. We may use your Information as part of our efforts to keep said Service safe and secure (for example, for the purposes of monitoring and/or preventing fraud).
  * To enforce our Terms and policies for Business Purposes, Legal Reasons and/or possibly Contractual Reasons.
  * To respond to legal requests and prevent harm for Legal Reasons. For example, if we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  * 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 an IQX Service, our products and services, our marketing and your experience.

=====6 - Will your Information be shared with anyone?=====

**In Short: We only share Information for Contractual Reasons, to fulfil our Business Purposes, or with your Consent**

We only share and disclose your Information in the following situations:

  * **Contractual.** We may share Information with brand providers and partners to enable any orders for products or services, or obligations arising out of any such orders, to be fulfilled.
  * **Compliance with Legal Obligations.** We may disclose your Information where we are legally required to do so in order to comply with applicable laws, governmental requests, judicial proceedings, court orders, or legal processes, such as in response to a court order or a subpoena (including in response to requests from public authorities in order 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, illegal activities or situations involving potential threats to the safety of any person, or where we believe it is necessary for the purpose of providing evidence in connection with litigation proceedings in which we are involved.
  * **Third Party Service Providers.** We may share your Information with third party vendors, service providers, credit reference agencies, trade associations of which we are a member, credit card associations, contractors or agents who perform services and require access to such Information to carry out that work. Examples include: data analysis, email delivery, hosting services, customer service and marketing efforts. Such third parties will only have access to your Information to the extent that they need to perform those services. They are required to keep your Information confidential and may not use it other than as we ask them to and always in accordance with this Policy.
  * **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.
  * **Business Partners.** Provided you have given us Consent to do so we may share your Information with our business partners to offer you certain products, services or promotions.
  * **With your Consent.** We may disclose your Information for any other purpose with your Consent, including with any person who you have named as a person we can contact to discuss your account and any agent or representative of yours.

We may disclose aggregated, anonymous Information (i.e. Information from which you cannot be personally identified), or insights based on such anonymous Information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of an IQX Service. In such circumstances we will not disclose any Information which can identify you personally.

=====7 - Is your Information transferred internationally?===== 

**In Short: We may transfer, store, and process your Information in countries other than your own, but will take all reasonable steps to ensure it is protected**

Whenever we transfer your Information outside of the UK, we will take all reasonably practicable measures to protect your Information in accordance with this Policy and applicable laws. To the extent that any transfer requires approved safeguards to be in place (for example, using the EU model contract clauses in connection with transfers outside of the European Economic Area, or other appropriate safeguards) we will ensure these measures are in place.

=====8 - Third Party Websites====
**In Short: We are not responsible for the safety of any Information that you share with third party providers who feature or advertise on any of our sites, but are not affiliated with, the IQX Services.**

The IQX Platform may feature links to third party websites or contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications.  We cannot guarantee the safety and privacy of data you provide to any third parties.  Any data collected by third parties is not covered by this Policy.\\ 
We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the IQX Platform.  You should review the policies of such third parties and contact them directly if you have any related questions.

=====9 - For How long do we keep your Information?=====

**In Short: We keep your Information for as long as necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is permitted or required by law.**

We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax law, accounting requirements or other legal or regulatory requirements).

When we have no ongoing Business Purpose to justify the processing of your Information, we will either delete or anonymise it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.

=====10 - How do we keep your Information safe?=====

**In Short: We aim to protect your Information through a system of organisational and technical security measures.**

We have implemented appropriate technical and organisational security measures designed to protect the security of any Information we process. For example, we store your personal data and company data on secure servers using encrypted databases.

We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory body of a suspected data breach where we are legally required to do so.

However, please also remember that we cannot guarantee that the Internet itself is 100% secure. Although we will use our reasonable endeavours to protect your Information, we cannot guarantee the security or integrity of personal Information that is transferred from you or to you via the Internet. Transmission of personal Information to and from the IQXanywhere Platform is therefore at your own risk. You should only access our services within a secure environment.

=====11 - Do we collect Information from minors? =====

**In Short: We do not knowingly collect data from or market to children under 16 years of age.**

We do not knowingly solicit data from or market to children under 16 years of age. By using an IQX Service, you represent that you are at least 16 years of age. If we learn that Information from users less than 16 years of age has been collected, we will deactivate the relevant 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 16 years of age, please contact us immediately via info@iqx.co.uk.

===== 12 - Your Consent to processing =====

You will be required to give Consent to certain processing activities before we can process your Information. Where applicable, we will seek Consent from you when you first submit Information to or through an IQX Service.

If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing info@iqx.co.uk.

If you withdraw your Consent, and if we do not have another legal basis for processing your Information, then we will stop processing your Information. If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal rights.

Please note that if we need to process your Information in order for you to use an IQX Service and you object or do not provide Consent to us processing your Information, you accept that said IQX Service will no longer be available to you.

===== 13 - Marketing and opting out =====

If you have given Consent to marketing we may contact you about our products, services, promotions and special offers. If you no longer wish to receive such Information, you can withdraw your Consent at any time by sending an email to info@iqx.co.uk or unsubscribing from the communications.

If you have given Consent, we may share your Information with carefully selected third party organisations and business partners and they may contact you directly. If you would prefer to no longer receive direct marketing communications from third parties and partners after previously giving your Consent, please contact those third parties and partners directly to withdraw the Consent. **We aren't likely to do this**.

Where you opt out of receiving marketing messages, this will not apply to personal data provided to us in connection with your purchase of a product or service or your involvement in other related transactions.

===== 14 - Account Information =====

If as a result of using any IQX Service, you create an account with us, you may review or change information in that account by logging into the account, or by communicating directly with us.
===== 15 - Your information and your rights =====

If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:

  * the right to be told how we use your information and obtain access to your information;
  * the right to have your information rectified or erased or place restrictions on processing your information;
  * the right to object to the processing of your information e.g. for direct marketing purposes or where the processing is based on our legitimate interests;
  * the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible ("data portability");
  * where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
  * the right to object to any decisions based on the automated processing of your personal data, including profiling; and
  * the right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in the UK, the Information Commissioner&#39;s Office).

If we hold any information about you which is incorrect or if there are any changes to your details, please let us know by so that we can keep our records accurate and up to date.

If you withdraw your consent to the use of your personal information for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our website, applications, and services.

We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with our Data Retention and Destruction Policy or as otherwise permitted by applicable laws and regulations. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).

=====16 - Contact us =====

We welcome your feedback and questions on this Policy. If you wish to contact us about this Policy or have any other questions, please email us at info@iqx.co.uk, write to us at Wester Newhouse, Lilliesleaf, Melrose TD6 9JT, United Kingdom, or call us on +44 (0)1835 340034.

You have the right to make a complaint at any time to the Information Commissioner's Office (the **ICO** ), the UK supervisory authority for data protection issues ([https://ico.org.uk/concerns](https://ico.org.uk/concerns/)). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

=====17 - Changes to the privacy policy =====

This Privacy Policy was last updated on [date]. We may change this Privacy Policy from time to time. However, we will not reduce your rights under this Privacy Notice. We will always update this Privacy Notice on our website, so please try to read it when you visit the website,

=====18 - Do you need extra help? =====

If you would like this policy in another format (for example: audio, large print, braille) please contact us via the details given above.