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Our Privacy Policy

Your privacy is important to us at 10x Future Technologies Limited (“10x”). We collect and process your personal data exclusively in accordance with the laws and regulations applicable in the UK as well as in accordance with the European General Data Privacy Regulation (“GDPR”). This privacy policy explains the nature, extent and purpose of our collecting and processing of your personal data.

1. Controller contact details

The controller responsible in accordance with data protection laws is (herein also called from time to time “controller”) 10x with company number 10146101 and based at 5 Howick Place, London, SW1P 1WG. For the purposes of data protection laws, 10x is registered as a data controller with the Information Commissioner’s Office (“ICO”) under number ZA491049.

If you have any questions regarding this privacy policy, please do not hesitate to contact us by email at dpo@10xbanking.com.

2. Data collected

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 website, we may collect, use, store and transfer different kinds of personally identifiable information 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 first name, last name, title

  • Contact Data: including email address and telephone number

  • Usage Data: including information about how you use our website, products and services such as date and time of accessing our website, name of the requested file/URL, Unique device identifiers and browser type

  • Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences

We 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.

When processing your Personal Data, 10x either relies on your consent or gathers the data as it is necessary for ensuring that we can provide a service to you and/or our legitimate interest in making you aware of related information.

The data will be held under 10x’s control.

3. How we collect your personal data

We use different methods to collect data from and about you including through:

  • Direct interactions: You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • apply for a demonstration of our service;

    • subscribe to our notification service or publications;

    • request information to be sent to you; or

    • give us feedback or contact us.

  • Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, logs and other similar technologies. Please see our Cookie Policy for further details.

  • Third parties: We may receive personal data about you from third party analytics providers such as Google Analytics (Technical Data)

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where you have consented to us using your personal data

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

  • Where we need to perform the contract that we are about to enter into or have entered into with you

  • Where we need to comply with a legal obligation

5. Purpose for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.

Purpose/Use

Type of data

Lawful Basis for Processing

To manage our relationship with you which may include:

(a)   Notify you about changes to our terms or privacy notice

(b)   Ask you to leave a review or take a survey 

(a)   Identity

(b)   Contact

(c)   Marketing and Communications

(a)   Necessary to comply with a legal obligation

(b)   Necessary for our legitimate interests (to keep our records updated and to study how individuals use our services

To deliver relevant marketing communications to you

(a)   Identity

(b)   Contact

(c)   Usage

(d)   Marketing and Communications

(e)   Technical

(a)   Consent

(b)   Necessary for our legitimate interests (to study how others use our services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, services, marketing, sales relationships and experiences

(a)   Usage

(b)   Technical

Necessary for our legitimate interests (to define types of individuals who may be interested in our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services and events that may be of interest to you

(a)   Identity

(b)   Contact

(c)   Usage

(d)   Technical

(e)   Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)


6. Direct marketing and opting 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. 

Where we gather your Personal Data for direct marketing purposes and rely on your consent, you will always be able to withdrawal that consent, although we may have other legal grounds for Processing your Personal Data for other purposes, such as a legitimate business interest.

However, you may unsubscribe from our marketing list at any time if you change your mind, as you have an absolute right to opt-out of directing marketing that we may carry out as a business. 

If you have consented to direct marketing and wish to opt out, you can do this by using the unsubscribe button in the email communication sent out to you or by contacting us using the details set out above.

7. Disclosures of your personal data

We may share your personal data with the parties set out below.

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.

7.1 Hubspot

10x uses Hubspot for purposes of marketing campaign analysis and customer relationship management. Hubspot is a service of Hubspot Inc., a US software company which also has a subsidiary in Ireland (contact: Hubspot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland)

In the course of the service, cookies are being placed and stored on your computer. Both enable us to analyse the performance of our marketing campaigns and allow users of our website to submit contact requests through online forms. The information stored (e.g., IP- address, geographical data, browser type, time, and duration of the visit) are analysed and evaluated by Hubspot on behalf of 10x to gain insights about your visit.

The use of Hubspot is based on our legitimate interest in appropriate design, statistical evaluation and the efficient use of our marketing campaign as well as managing relationships with our customers.

Additional information about the functionality of Hubspot, can be found in the privacy policy of Hubspot Inc., which can be downloaded here: https://legal.hubspot.com/privacy-policy

7.2 Prospective and existing customer management (Salesforce)

We use Salesforce, a customer relationship management software by Salesforce.com, inc.  With Salesforce we collect personal identifiable information on customers, partners, prospective customers, and prospective partners. The information is directly captured via a sales related form. Customers need to provide the following required inputs for support enquiries:

  • First name, last name

  • Company email address

This data is required to create an associated record in our customer relationship management software to manage and process your data for the following purpose:

  • If you are a prospective or existing customer of 10x, to support the communication process with you.

7.3 International transfers

We share your personal data within the Hubspot and Salesforce Group. This may involve transferring your data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • 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 European Commission; or

  • Ensure that a legally approved transfer mechanism is used such as Standard Contractual Cluses, to implement the international transfer.

7.4 Legal requirements

10x Future Technologies may disclose your Personal Data in the good faith belief that such action is necessary:
data

  • To comply with a legal obligation

  • To protect and defend the rights or property of 10x Future Technologies

  • 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


8. Retention of data

We take every commercially reasonable step to ensure that your Personal Data is only Processed for the minimum period necessary for the purposes set out in this Notice. When deciding how long to keep your personal data, we consider the factors including:

  • Legal obligation(s) under applicable law to retain data for a certain period of time.

  • Whether we relied on your consent to use the Personal Data, but you have since withdrawn your consent.

  • Our legitimate interests where we have carried out balancing tests.

  • Statute of limitations under applicable law(s),

  • (potential) disputes and legal claims; and

  • Guidelines issued by relevant data protection authorities.

  • Retention of your Personal Data is necessary in connection with the lawful purposes set out in this Privacy Notice, for which we have a legal basis.

Once the necessary retention has passed, 10x will permanently delete relevant Personal Data.


9. Security of data

We have put in place appropriate 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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. The security of your data is extremely important to us however no method of transmission over the Internet, or method of electronic storage is 100% secure.


10. Your rights

10.1 Your rights

 The UK GDPR provides individuals with specific rights around their data.

  • You have the right to be informed about how 10x uses your personal data.

  • You have the right to access and ask for a copy of your data (commonly known as a “data subject access request”) and to obtain the personal 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.

  • You have the right to ask 10x to correct/rectify the personal data that we hold about you. This enables you to have an incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to 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.

  • 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.

  • 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. 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.

  • You have rights in relation to automated decision making and profiling.

  • You can also object to the processing of your personal data in some 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).

  • 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.

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.

If you wish to exercise any of these rights, including making a data subject access request (“DSAR”) to obtain copies of your data, you can get in touch with us using the details set out at the top of the page.

For more information about your rights, please look at the following ICO page: Individual Rights | ICO.

10.2 No fee usually required

You will not usually have to pay any fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

10.3 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.

10.4 Time limit to respond

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 a number of requests. In this case, we will notify you and keep you updated.


11. 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.


12. Making a complaint to a supervisory authority

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.


13. Amendments of our privacy policy

We keep our privacy notice under regular review. The current version of this privacy notice is always available at 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.


Contact Us

If you have any questions about this Privacy Policy, please contact us by email: dpo@10xbanking.com