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Privacy Policy

Your privacy is important to us at 10x Banking Technology Services Ltd. (“10x”). To provide you with control and transparency of your Personal Data, this privacy notice addresses how we collect, use and share (collectively referred to as ‘process’ or ‘processing’) your information in connection with your use of 10x’s websites, social media pages, your interactions with 10x during in-person meetings or at 10x events, and in the context of other online or marketing activities.

1. OUR ROLE

If you use, browse, or visit any of 10x’s websites or otherwise interact with 10x, we may use, collect, and store Personal Data that has been collected or received from you or about you.

We process data in the following cases:

 

Direct interactions

When you make use of or interact with our websites, https://www.10xbanking.com and https://docs.10xbanking.com (‘Websites’) by:

  • Sending a request or applying for a demonstration of our services.
    • Subscribing to our mailing list and publications.
    • Giving us feedback or contacting us.
    • Requesting to read more of our whitepapers, data sheets and other resources that we have on our website or third-party sites.
    • Accepting cookies
  • Attending one of our events, webinars and/or we exchange business cards.
  • Corresponding with us by phone, email or otherwise.
  • When you subscribe to our newsletter(s) / blogs(s).

Automated technologies or interactions

As you interact with our Websites, we will automatically collect technical / usage data about your device, browsing actions and pattern e.g. your device’s IP address. We collect this Personal Data by using cookies, logs, and other similar technologies. Please see our Cookie Policy for further details.

Third Parties

When we obtain Personal Data about you from third party providers including:

  • analytics providers such as Google Analytics and Lead Forensics (Technical Data),
  • third party event hosts such as BrightTalk,
  • professional and social networking platforms such as LinkedIn.
 
Please read this Privacy Policy carefully, so you can fully understand our practices and processes in relation to your Personal Data.

2. TYPES OF DATA WE COLLECT

''Personal Data’ or ‘Personal Information’ means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

While using our Websites or interacting with 10x, we may collect, use, store and transfer different kinds of Personal Data about you that can be used to contact or identify you. This information has been grouped below and may include, but is not limited to:

  • Identity Data: including your first name, last name, title and company name
  • Contact Data: including your email address and telephone number
  • Location data: including country, state, or city.
  • Usage Data: including information about how you use our Websites, products/ services viewed, date and time of accessing our Websites, name of the requested file/URL, unique device identifiers and browser type
  • Marketing and Communications Data: information about your preferences in receiving marketing from us and your communication preferences
  • Cookies data: includes geolocation data, IP address cookie preference and usage data.

We also use Lead Forensics’ IP Tracking tool, which identifies businesses visiting our Websites and the pages that they visit. Lead Forensics will not be used to identify the individual visiting the Websites, only the company, and provides us with information readily available in the public domain, including the visiting company’s contact information.

You can learn more by going to Lead Forensics’ website.

 

What about Special Categories of Personal Data or Children’s data?

10x is a business-to-business service and we do not target children or knowingly collect any Personal Data from any person under 16 years of age.

We also do not collect any Special Categories of Personal Data about you (this would include for example details about your race or ethnicity, religion or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT AND HOW IT IS USED

Data protection law ensures that we can only use your Personal Data for certain reasons and where we have a lawful basis to do so. The table below sets out the reasons for which we process your data and the legal basis we rely on when doing so:

  • Purpose

    Why is the personal data collected

    Type of data

    What data are we collecting (defined above)

    Lawful Basis for Processing

    Applicable under GDPR

    Perform analytics, statistics, and marketing when you visit the 10x Websites
    • Usage data
    • Cookies data
    • Marketing and Communications data
    Consent (non-essential cookies)

    Legitimate interest (essential cookies – e.g., use data analytics to improve our websites, services, marketing, sales relationships, and user experiences)
    To provide you with a demo or further information on partnerships
    • Identity data
    • Contact data
    • Location data
    Legitimate Interest (e.g., to communicate with you, to grow our community, improve our services and to generate business leads)
    To respond to your request once you have contacted us (e.g. when you have submitted a request via our Websites)
    • Identity data
    • Contact data
    • Location data
    Legitimate interest (e.g., to answer your question, provide support, B2B marketing and/or give you more information about 10x’s products and services)

    Ask you to leave a review or feedback

    • Identity data
    • Contact data
    Legitimate Interest (to improve our services, to inform our strategies)
    To provide you with our resources including whitepapers, data sheets and other material we make available on the 10x Websites or any other third-party website including LinkedIn
    • Identity data
    • Contact data
    • Location data
    Legitimate Interest (e.g., to download our resources, grow our business, expand our community, and send you marketing communications)
    Add you to our mailing list and/or newsletter to send you marketing communications, information about 10x, updates and other materials
    • Identity data
    • Contact data
    • Location data
    • Usage data
    • Marketing and Communications data

    Depending on the context:

    Legitimate Interest (e.g., establish a business relationship, develop our partner network and to provide you with information about 10x, our products and services, events, blogs, webinars, and other relevant material)

    Consent

    To establish a business relationship with businesses within our target market
    • Identity data
    • Contact data
    • Location data
    • Usage data
    Legitimate interest (B2B marketing and/or to provide you with information with our services and product)
    To interact with you on our social media platforms
    • Contact data
    • Identity data
    Legitimate Interest (e.g., establish a business relationship, to develop our partner network, to grow our community)
    To communicate with you as part of our sales process
    • Identity data
    • Contact data

    Legitimate Interest (e.g., to establish a B2B relationship)

    Pre-contractual/Performance of a contract

    To record your Cookie preferences

    For more information about our use of Cookies, please see our Cookie Policy
    • Identity
    • Usage
    Necessary to comply with a legal obligation



4. DIRECT MARKETING AND RIGHT TO OPT-OUT

You are not under any statutory or contractual obligation to provide your Personal Data to 10x, and we strive to provide you with choices regarding certain Personal Data uses, particularly around marketing communications. Our marketing team will ensure that 10x’s marketing communications are tailored and relevant to the recipients and kept to a reasonable and proportionate level.

You can opt-out of receiving marketing communications from us at any time by using the unsubscribe link in the email communications we send.

5. YOUR RIGHTS

5.1 Your rights

You have multiple privacy rights, subject to applicable law, in respect to the information we process about you. You can exercise your rights by sending an email to DPO@10xbanking.com.

Right to be Informed

You have the right to be informed about how 10x uses your Personal Data.

Right to Access

You have the right to access and ask for a copy of the data we hold about you (commonly known as a “data subject access request”). This right extends to obtaining the data in a structured, machine-readable format.

This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you as soon as we can and keep you updated.

Right to correction and rectification

You have the right to ask 10x to correct or rectify the Personal Data that we hold about you.

This enables you to have an incomplete or inaccurate record we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Right to be ‘forgotten’ by us

You have a right to request erasure of your Personal Data.

This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it.

You also have a right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law.

Note, however, that we may not always be able to comply with your request of erasure for specific leal reasons which will be notified to you, if applicable, at the time of your request.

Right to request restriction

You have a right to request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Right to port your data to another service

You have a right to ask us to share (and/or port) your data to another controller. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format such as in CSV or JSON. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. We will not share information that involves disclosing data about any other individual.

Object to us using your data for profiling or making automated decisions about you

We may use your data to determine whether we should let you know about information that might be relevant to you (for example, tailoring emails based on your behaviour).

Right to object

You can also object to the processing of your Personal Data in other circumstances. In particular where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to the processing on this ground as you feel it impacts on your fundamental rights and freedoms and where we are using your Personal Data for direct marketing.

Right to withdraw consent

You have a right to withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw consent.

If you withdraw your consent, we may not be able to provide information about our services to you. We will advise you if this is the case at the time you withdraw your consent.

Right to lodge a complaint regarding our use of your Personal Data

Should you be dissatisfied with the Service that 10x provides, you have the right to file a formal complaint to the ICO at www.ico.org.uk, or to the relevant data protection supervisory authority in your country of residence.

However, we would prefer if you raised any complaints with us directly in the first instance, so that we can try our best to resolve the issue for you and, if you are dissatisfied with our response, you can then take the matter to the relevant data protection supervisory authority, such as the ICO.

5.2 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

However, please remember that these rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemption we rely upon when responding to your requests.

6. HOW WE SECURE YOUR DATA

We have put in place appropriate operational and technical security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.

The security of your data is extremely important to us however please remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. If you believe your privacy has been breached, please contact us immediately on DPO@10xbanking.com.

7. RETENTION OF YOUR DATA

We take every commercially reasonable step to ensure that your Personal Data is processed for the minimum period necessary for the purposes set out in this Notice.

We constantly monitor engagement with our direct marketing activities. If you have not engaged with 10x within 18 months, then we will delete your personal data from our systems unless we continue to have a legitimate interest to process your information.

For the retention of data collected through our cookies, please see 10x’s Cookie Policy.

8. DISCLOSURES OF YOUR PERSONAL DATA

8.1 Transfers within the 10x Group and to third parties

We may share your Personal Data within the 10x Group, or with third parties where required by law or where we have a legitimate interest in doing so.

"Third parties” include third-party service providers and the following activities may be carried out by our third-party service providers:

  • Platform providers
  • Marketing, sales, and service software providers
  • Fulfilment providers
  • Professional services

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

We may share your Personal Data with third-party partners where we have a legitimate interest to do so, such as when you attend an event that is co-hosted by 10x and another partner.

8.2 International transfers

We may share your Personal Data outside the UK and / or the EEA either with our third-party providers or within the 10x Group.

Whenever we transfer your Personal Data outside of the UK (for example to third parties who provide us with a service in a third country), we ensure a similar degree of protection is afforded through one of the following safeguards:

  • We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the UK government or the European Commission; or
  • Ensure that a legally approved transfer mechanism is used such as Standard Contractual Clauses, or the International Data Transfer Agreement (IDTA) to implement the transfer where the receiving country does not benefit from adequacy by the UK government or European Commission.
  • We have an intra‑group data transfer agreement in place which regulates cross‑border transfers of personal data within the 10x group.

You can obtain a copy of any standard contractual clauses in place which relate to transfers of your Personal Data by contacting 10x’s DPO, DPO@10xbanking.com.

You have a right to request a copy of any data transfer agreement under which your Personal Data is transferred, or to otherwise have access to the safeguards used. Any data transfer agreement made available to you may be redacted for reasons of commercial sensitivity. To request sight of these contact contacting 10x’s DPO, DPO@10xbanking.com.

8.3 Legal requirements

10x Banking Technology Services Ltd. may disclose your Personal Data in the good faith belief that such action is necessary:

  • To comply with a legal obligation
  • To protect and defend the rights or property of 10x Banking Technology Services Ltd.
  • To prevent or investigate possible wrongdoing in connection with the Service.
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

9. LINKS TO OTHER SITES

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

10. CHANGES TO OUR PRIVACY POLICY

We keep our privacy notice under regular review. The current version of this privacy notice is always available at https://www.10xbanking.com/privacy-policy. Please note that we may change or update this policy from time to time. We will publish the corresponding changes at the above-mentioned link.

11. CONTACT US

Controller Details

10x Banking Technology Services Limited

33 Holborn, London EC1N 2HT

ICO Registration Number: ZA491049

 

Data Protection Officer

Data Protection Officer: Helisa Shamloo

Email Address: DPO@10xbanking.com

 

Last Updated: September 2022