We are Xto1 Ltd, a company registered in England under company registration number 10442585 (and we refer to ourselves as “Xto1”, “we”, “us” or “our” in this document).
Xto1 is committed to protecting and respecting your privacy. We ask that you please read the following carefully to understand our views and practices regarding your personal data and how we, as data controller of your personal data, may use, process and store your personal data.
The Laws and Regulations
The laws that govern personal data in the UK are:
- The Data Protection Act (1998)
- REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”).
The independent authority that upholds information rights in the public interest in the United Kingdom is the Information Commissioner’s Office (the “ICO”).
Information we may collect from you
Xto1 may collect information from you because we have a legal reason (permitted by law or under contract) to collect the information, or because you have consented for us to do so for a specific purpose.
Information we collect from you directly
When you register on www.xto1.com (the “Website”) or the Xto1 mobile app (the “App”), or you post any request through us, or contact our Customer Support, we may ask for some or all of the following information: your name, email address, phone number, postcode, address, occupation, skills, types of work that you may be interested in receiving.
Information we collect from your activity on the Website or App
As you use the Website and/or App, we may automatically collect information about your activity on the Website and/or App. This includes things like your IP addresses, information about what type of device or software you use, unique device identifier, location, information about how you use the Website and/or App, your communications with Xto1 and/or other Xto1 users, and other information related to your activity, such as which website referred you to us.
Information we receive from other sources
We may receive information about you from third party sources, such as data aggregators and from third parties to whom you have given permission to share your information or from whom you have given us permission to request your information. For instance, by registering for the Website and/or App using Gmail, Facebook or another network, you grant permission to that network to share your details. The specific information provided to us by such third party networks is determined by these networks and may vary by network.
We also work with third parties (including, for example, business partners, sub-contractors, advertising networks, analytics providers, search information providers, credit reference agencies, background checking agencies) and may receive information about you from them as part of the service we provide you, or for legal reasons.
Why Xto1 collects personal data
We use the personal data we collect to provide the Website, the App, the services on the Website and/or App and services related to them, to customise and improve your experience with Xto1, to make your experience as enjoyable and efficient as possible and for commercial purposes.
Use of Information to Provide the Services
Certain information is required in order for the Website and/or App to operate.
Here are some specific examples of information used:
- Your email address and password allows us to recognise you when you return so that we can provide you with a faster service and a personal user account.
- Your postcode and address allows us to identify your location and identify other users local to you, so we can match you with local service providers and/or local customers.
- We use your IP address and phone number to prevent any spam, fraud or abuse of our Website and/or App.
- We use your login data to allow you to post or respond to requests.
- To facilitate your use of the Website, we may (or your browser may) pre-populate certain fields in the forms. If we do so, it will be for fields for which we already hold your information, such as your name, email address, phone number and postcode. You always have the opportunity to delete any fields that we pre-populate.
- When you post a request on the Website and/or App, we will ask you for your name, your phone number, email address and postcode (among other things). On subsequent requests, we may pre-populate these fields for you with the information previously provided. You always have the opportunity to amend any fields that we pre-populate before posting the requests.
- We use information collected by us on transactions you have completed to monitor service quality levels and to provide service and support to Xto1 users in general and for individual transactions.
Use of information to customise and improve the Xto1 experience
We want your experience with us to be as enjoyable as possible. We will collect information about your activities and preferences to customise your account (in addition to how you customise it yourself) and to enable us to provide an efficient and user-friendly service. We will also use it to improve the quality of the Website and App.
Here are some specific examples of how we use your information:
- We keep details of requests you posted and responded to, and we may make this information available to you via for your review and record-keeping purposes.
- We may keep a record of certain of your preferences, so you don’t need to reset these preferences every time you use the Website and/or App.
- We keep a record of your login details to make it faster for you to place orders in the future so that you do not continually have to re-enter such details.
- Paying attention to how you use the Website and/or App helps us to develop improvements to the Website and/or App and the services we offer.
- If you have been referred to us by a third party website, we may keep a record of the website that referred you so that we may work out which websites refer more or less users to our Website and/or App. We may also have referral arrangements with certain third party websites and referrers and we may use this data to fulfill obligations that we may have to these third party websites or referrers.
- We collect and track individual and aggregate information about service preferences and selections which users have made and the like. We use this information for the personalisation or general improvement of the goods and service we offer, but also for the purpose of business research. You can see more about aggregate information below.
- We collect and track individual and aggregate connection information such as device brand and model, browser type and version, operating system and platform; other software and hardware information and the like. We use this information to understand how and when our users access our online services, and so we can further develop our Website and App and services to suit.
Use of Information for Commercial Purposes
We may earn revenues through sources including advertising sales, including online behavioural advertising, including personalised retargeting advertising, and through the sale of business intelligence data.
Here are some specific examples of how we may use your information:
- We may share information with certain carefully selected third party partners so that they can:
- present you with advertisements and promotional offers that are relevant to you and your interests or, alternatively.
- to present you with advertisements on Xto1 based on your activity on other websites.
- We collect and may display or use information for the purposes of marketing and advertising the Website and/or App, our services or ourselves, any testimonials or reviews you provide us with about the Website and/or App, our services or ourselves, or other Xto1 users – and we may append to the testimonial or review your name and general geographic location (e.g. City or locale).
Use of Your Email Address
We use your email address to communicate with you. Some of these are service emails and are so we can communicate with you about Website and/or App updates or your activity on the Website and/or App. For instance, we may send you service emails:
- notifying you of your registration details, or helping you to reset password.
- after you have posted a request, to confirm the request and update you on the status of the request and responses received.
- to send you information which you have asked for.
- to contact you about the status of ratings or reviews you have submitted or received.
Aggregate information is data we collect about a group or category of services or users, from which individual user identities have been removed and from which it is not possible to work out individual customer identities. In other words, information about how you use a service may be collected and combined with information about how others use the same service, but all such information will be anonymised and no identifying information will be included in the resulting data.
Aggregate data helps us to understand trends and customer needs so that new products and services can be considered and so that existing products and services can be tailored to customer desires. We use and disclose anonymised aggregate information to provide other products and services, as well for the purposes of evaluating and improving our existing products and services. We may also sell such aggregate information through business channels.
What legal basis Xto1 has for processing your information
Xto1 may process your information because:
- You have given us permission to do so
- We want to provide services to you after you have requested such services from us
- We have to provide services to you because we are legally or contractually obliged to do so
- To comply with the law.
All of these reasons are reasons Xto1 may legally process the information we have about you.
Who Xto1 might share your information with
Xto1 may share your personal data with third parties, in order to allow us to operate the Website and/or App, to provide the services to you, for corporate or statutory purposes or as part of a partnership with a third party. For example, we may share your personal data with:
- Other Xto1 users who have responded to your request
- Other Xto1 users who posted the request you responded to
- Subcontractors and third parties for the purpose of the performance of a contract that we hold with them or that we hold with you
- With third parties because you have given consent
Other reasons Xto1 may share your personal data with a third party
- We may transfer our databases containing your personal data if we sell our business or part of it and engage in another similar corporate transaction.
- We will share personal data where we are required to share your personal data in order to comply with any legal obligation.
- We will share personal data where it is required to protect the rights, property, or safety of Xto1, Xto1 users or others
- We will exchange information with other companies or organizations to prevent fraud or to reduce our credit risks.
Aggregated or anonymized data with personal data removed
We may, from time to time, provide third parties with data that has been aggregated or anonymized. This means that your personal data that could be used to identify you have been removed from the data. Data provided to third parties in this way is not personal data; however, you do keep your right to object.
Where Xto1 stores your personal data
We primarily store and process your personal data in the EU/European Economic Area (“EEA”). If we do transfer your personal data outside the EEA it will be because you have consented or because we have a legal reason to do so.
Some examples of reasons your data may be processed outside of the EEA include:
- Technical support services.
If your personal data cannot be processed within the EEA, we will:
- Comply with all other data protection principles
- Where possible, be to a country that is on the list of the EU Commissions’ countries that provide adequate protections for the rights and freedoms of data subjects
- If the transfer is to the United States of America, we will use reasonable endeavours to make sure they participate in the Privacy Shield program
- Make sure we have assessed the adequacy of protections in all other cases.
Access to your stored personal data via password
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website and/or App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Transmission and storage of your personal data
Unfortunately, the transmission of information via the internet is not completely secure. Although we use best practice to ensure your data is encrypted to the standard required in the GDPR to protect your personal data, we cannot guarantee the security of your data as it is transmitted and stored.
How long Xto1 will keep your personal data
We will not retain your personal data for longer than required.
We will keep your personal data:
- For as long as required by law
- Until we no longer have a valid reason for keeping it
We may keep just enough of your personal data to ensure that we comply with your requests not use your personal data or comply with your right to erasure. For example, we must keep your request to be erased even if it includes your personal data.
What if you chose not to give us your personal data?
If the personal data is necessary in order to provide the services to you, then we will not provide the services if you do not give us your personal data.
We will respect your legal rights to your data.
Below are the rights that you have under law, and what Xto1 does to protect those rights:
The right to be informed
The right to access
You have the right to access your information. If you wish to access the personal data Xto1 holds about you, please contact Xto1 Customer Support at email@example.com.
The right to rectification
If the information Xto1 holds about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we will also ask them to rectify the data. If you need us to rectify your information, please contact Xto1 Customer Support at firstname.lastname@example.org.
The right to erasure
This is sometimes called ‘the right to be forgotten’. If you want Xto1 to erase all your personal data and we do not have a legal reason to continue to process and hold it, please contact Xto1 Customer Support at email@example.com.
The right to restrict processing
You have the right to ask Xto1 to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future. If you want us to restrict processing of your data, please contact Xto1 Customer Support at firstname.lastname@example.org.
The right to data portability
Xto1 must allow you to obtain and reuse your personal data for your own purposes across services in a safe and secure way without this effecting the usability of your data. If you want to port your data elsewhere, please contact Xto1 Customer Support at email@example.com. This right only applies to personal data that you have provided to us as the Data Controller. The data must be held by us by consent or for the performance of a contract.
The right to object
You have the right to object to Xto1 processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purpose of statistics. If you wish to object, please contact Xto1 Customer Support at firstname.lastname@example.org.
The right to withdraw consent
If you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and Xto1 must stop processing your data. If you want to withdraw your consent, please contact Xto1 Customer Support at email@example.com.
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