Your privacy is important to us at 10x Banking Technology Services Ltd. (“10x”). Here is how we collect, process and protect your personal data in accordance with the UK General Data Protection Regulation.
1. Our role in your privacy
If you are a user of the 10x website or a subscriber to one of our marketing lists, 10x will act as the ‘data controller’ of the personal data that is collected on you. This means we determine how and why your data is processed and to find out more information, you should read this policy.
We are registered as a data controller at the UK Information Commissioner’s Office under ZA491049, with company number 11262659 and the following registered address 5 Howick Place, London, SW1P 1WG.
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 website, we may collect, use, store and transfer different kinds of personally identifiable information 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, company
Contact Data: including your email address and telephone number
Usage Data: including information about how you use our website, products/ services viewed, date and time of accessing our website, 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.
What about Special Categories of Personal Data or Children’s data?
10x is a business-to-business service and we do not target children at 10x 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. 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.
Third parties: We may receive personal data about you from third party analytics providers such as Google Analytics (Technical Data)
4. How and why we use your personal data
Data protection law ensures that we can only use your personal data for certain reasons and where we have a legal 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:
Type of data
Lawful Basis for Processing
To manage our relationship with you which may include:
(a) Contacting you when you request a demo or further information on partnership
(b) Ask you to leave a review or take a survey
(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
(d) Marketing and Communications
(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
To record your Cookie preferences
Necessary to comply with a legal obligation
Here is some more information on what each ‘legal basis’ means
You have given clear consent for us to process your personal data for a specific purpose. If you have previously given consent to our processing your personal data you can freely withdraw such consent at any time. Please see below on how you can do this.
Processing your data is necessary for our legitimate interest or the legitimate interests of a third party, provided those interests are not outweighed by your rights and freedoms. These legitimate interests include:
- Gaining insight from your behaviour on our website
- Delivering, developing, and improving our website and services
- Enabling us to enhance and customise our services and communications
- Determining whether marketing campaigns are effective
- Enhancing our data security.
Sometimes we are obliged to process your personal data to comply with the law.
5. 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. Our marketing team will ensure that 10x’s marketing is tailored and relevant to the recipients and is kept to a reasonable and proportionate level.
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.
6. Your rights
6.1 Your rights
The UK GDPR provides you with specific rights around your data. 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 a number of 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.
6.2 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.
7. How secure is the data we collect?
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.
8. Retention of your data
We take every commercially reasonable step to ensure that your persona data is processed for the minimum period necessary for the purposes set out in this Notice.
We will archive and stop actively using your personal data for direct marketing purposes within 18 months from the last time you interact with 10x. We will then delete your personal data from our archives list no later than 3 years from the last time you used or interacted with 10x.
9. Disclosures of your personal data
9.1 Transfers to third parties and within the 10x Group
We may share your personal data 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.
9.2 International transfers
We may share your personal data outside the UK and / or the European Economic Area (EEA) either with our third-party providers or within the 10x Group.
Whenever we transfer your personal data to a third country, 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 UK government or the European Commission; or
- Ensure that a legally approved transfer mechanism is used such as Standard Contractual Clauses, to implement the international transfer.
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.
9.3 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
10. Links to other sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
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.
Last Updated: September 2021