Xplore – PRIVACY AND COOKIE POLICY

Who We Are

Xplore Local Ltd gather and process your personal information in accordance with this privacy notice and in compliance with the General Data Protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

Xplore Local Ltd’s registered office is at Newark Works, 2 Foundry Way, South Quays, Bath BA2 3DZ and we are a company registered in England and Wales under company number 7503285. We are registered on the Information Commissioner's Office Register; registration number ZA321178 and act as the data controller when processing your data. You can contact us by emailing us at support@xplorelocal.com

Information That We Collect

Xplore Local Ltd processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.

Information that you give us:

This is information about you that you give us by filling in forms on our site or our app or by corresponding with us by phone, email or otherwise. It includes information you provide when you register to use our app, subscribe to our service and when you report a problem with our site or with our app. The information you give us may include your name, address, email address and phone number. Xplore also collects personal data relating to merchants (when they sign up to Xplore) and from partners of Xplore. Such information is collected for the purposes of carrying out anti-money laundering and know-your-customer checks and to store the contact details of the merchant against the merchant’s account. Examples of this personal data include name, home address, date of birth, photographic identification documents (such as a copy of a company director’s passport), pay out bank account information (such as account name, account number and sort code.)

Information that we collect about you:

Regarding each of your visits to our site or our app we will automatically collect the following information:

• technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, operating system and platform.
• information about your visit, including the amount and payee of any transaction, location data, download errors and any phone number used to call our customer service number.

Information we receive from other sources:

This is information we receive about you if you use any of the other websites we operate or the other services we provide. This may also include any information already in the public domain e.g. Experian. We also receive information about you from our payment processor Yapily.

How We Use Your Personal Data

Xplore Local Ltd will never sell your data. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice.

We use the information we collect for the following purposes:

• As part of our contractual agreement with you to provide you with our services and to improve, promote and protect our services and to keep your account secure. To set up and administer your account, contact you and customise your experience on Xplore.
• To fulfil any legal or statutory obligations
• To enable us to occasionally send you marketing information where we have assessed that it is beneficial to you as a customer and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests. You may opt out of this marketing at any time.

Your Rights

You have the right to access any personal information that Xplore Local Ltd processes about you and to request information about: -

• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable - although this will result in us being unable to provide you with some/all of our services) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information other than for the purposes specified in this notice, where there is a legal requirement or if we were ever to sell, transfer or merge parts of our business. Xplore Local Ltd uses third parties to provide the services and business functions below; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

Safeguarding Measures

Xplore Local Ltd takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure, or destruction and have several layers of security measures in place, including: -

SSL, TLS, encryptions, pseudonymisation, restricted access, IT authentication, firewalls, anti-virus/malware.

Transfers Outside the UK and EU

Xplore Local Ltd may utilise some products or services (or parts of them) that may be hosted/stored in the USA or Canada which means that we may transfer any information which is submitted by you through the website outside the UK and European Economic Area ("EEA") for the below purposes: -

Marketing databases (Hootsuite, Mailchimp, Intercom), cloud applications (Trello, Atlassian, Loggly, Typeform, Trello), Electronic Document Signatures (Docusign)

Therefore, when you use our app or website or send us an email, the personal information you submit may be stored on servers which are hosted out-with the UK or EEA. Where this is the case, we will take steps to ensure that those providers use the necessary level of protection for your information and abide by strict agreements and measures set out by UK Data Protection and EU General Protection Regulations. i.e., Privacy Shield or binding corporate agreements.

Consequences of Not Providing Your Data

You are not obligated to provide your personal information to Xplore Local Ltd however, as this information is required for us to provide you with our services, we will not be able to offer all our services without it.

How Long We Keep Your Data

Xplore Local Ltd only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations.

Special Category Data

Owing to the services that we offer, Xplore Local Ltd sometimes needs to process sensitive personal information (known as special category data) about you, to perform identity checks and to satisfy anti- money laundering regulations. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.

Marketing

As noted in the ‘How We Use Your Personal Data’ section of this notice, we sometimes process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.

We may tailor marketing communications or send targeted marketing messages via app, social media and other third-party platforms; we may also provide existing customers with information (via email or other channels) about similar products and services. To improve the services we offer via our website and app, we may ask you to participate in research from time to time. It is entirely up to you whether you choose to do so.

We will use profiling, including segmentation tools and carry out research and analytics activities to inform our marketing strategies, to create a better understanding of our customers and visitors; and use of our website and app, to support our content presented, and to better improve the information, functionality and the services we provide.

To provide you with location-specific options, functionality or offers if you elect to share your Geolocation Information through the Services. We will use this information to enhance the security of the Sites and Services and provide you with location-based Services, such as advertising, search results, and other personalised content.

We may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products, services and offers for different customer segments, and to manage our relationships with them. It also helps us tailor the marketing that individuals receive or are shown on our own and other websites and mobile apps, including social media.

All marketing will have been identified as being beneficial to our customers and in our interests. Such information will be relevant to you as a customer and is non-intrusive and you will always have the option to opt-out/unsubscribe at any time.

Cookies

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site more relevant to your interests. We may also share this information with third parties for this purpose.

Lodging A Complaint

Xplore Local Ltd only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.

Xplore Local Ltd
Newark Works
2 Foundry Way
South Quays
Bath
BA2 3DZ
support@xplorelocal.com https://www.xplorelocal.com

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
0303 123 1113 casework@ico.org.uk https://ico.org.uk