- Data is processed fairly and lawfully
- Data is processed only for specified and lawful purposes
- Processed data is adequate, relevant and not excessive
- Processed data is accurate and, where necessary, kept up to date
- Data is not kept longer than necessary
- Data is processed in accordance with an individual’s consent and rights
- Data is kept secure
- Data is not transferred to countries outside of the European Economic Area (‘EEA’) without adequate protection
Lawful Basis of Processing Data
The lawful basis of processing of data will always be determined prior to any data being processed. Xtravirt processes personal data under one, or more, of the following Lawful Bases in accordance with GDPR:
- Consent – the individual has given their Consent to the processing of their personal data
- Contractual – processing of personal data is necessary for the performance of a contract to which the individual is a party, or for Xtravirt to take pre-contractual steps at the request of the individual
- Legal Obligation – processing of personal data is necessary for compliance with a legal obligation to which Xtravirt is subject
- Legitimate Interests – processing of personal data is necessary under the Legitimate Interests of Xtravirt or a Third Party, unless these interests are overridden by the individual’s interest or fundamental rights
Type of Personal Data collected
The type of personal data collected may include:
Demographic information such as postcode
How Personal Data is collected
Personal data is obtained from one or more of the following:
Visits and use of the above Xtravirt websites, and Company portals
Use of Xtravirts’ social media
Use of Google Analytics
Attendees of corporate seminars and webinars hosted by Xtravirt
Subscribers to Xtravirt Company updates
Parties entering into agreements with Xtravirt
Requests for information about products and services offered by Xtravirt, and/or quotes
Why Personal Data is collected
Personal data is collected to provide legitimate business services which include: For Marketing purposes
For us to review and reply to your enquiry
To provide an opinion for a service you have requested
To meet our statutory monitoring and reporting responsibilities
To handle and communicate orders, billings and payment, delivery of products and services To improve Xtravirts’ services and product offering
However, where indicated, some of the information is optional and you can choose not to complete.
How Personal Data is used
Personal data may be used to:
- process orders, process a request for further information, to maintain records and to provide pre and after-sales service.
- pass to another organisation to supply/deliver products or services you have purchased and/or to provide pre or after- sales service;
- pass onto our partners in order to follow-up on any webinars & events that you have registered for;
- carry out our obligations arising from any contracts entered into by you and us;
- carry out security checks (this may involve passing your details to our Identity Verification partners, who will check details we give them against public and private databases – this helps to protect us from credit risk and both you and us from fraudulent transactions);
- comply with legal requirements;
- assist third parties to carry out certain activities, such as processing and sorting data, monitoring how customers use our site and issuing our emails for us;
- seek your views or comments on the services we provide;
- notify you of changes to our services;
- send you communications which you have requested and that may be of interest to you. These may include information about product updates, newsletters, events, webinars;
- inform you of various promotions, goods and services that may be of interest to you. You may be contacted by post, email, telephone, SMS or such other means with carefully selected marketing communications we deem relevant to send to you in the legitimate interests of Xtravirt as an IT service provider. Each marketing communication sent to you by Xtravirt will provide you with the option to unsubscribe and manage your data profile and communication preferences from Xtravirt at any time;
- process a job application;
Where Personal Data is Stored
Information collected is stored on the Company’s CRM system and/or email marketing platform.
As part of any services offered by Xtravirt, information provided may be transferred to countries outside the European Economic Area (‘EEA’) i.e. our servers, or third party servers that are used to provide Xtravirt services located in a country outside the EEA. By submitting your data, you consent to the transfer, storage and/or processing of your data wherever it be stored. However, if your data is transferred outside the EEA, steps will be taken to ensure appropriate security measures are in place to ensure your privacy rights continue to be protected as outlined in this Policy.
How long Personal Data is stored
We review our retention periods for personal data on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations. We will hold personal data on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.
Who has access to Personal Data
Only Xtravirt employees are granted access to customer data. This is ensured by the use of strict operational processes and procedures.
Staff are trained on security systems and relevant processes and procedures which are reviewed regularly for ongoing effectiveness and suitability for purpose. All employees are kept up-to-date on the Xtravirt security and privacy practices. Employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure that customer information is protected.
Non-sensitive details (your email address and other requested information) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.
We will not sell or rent your information to third parties.
Third Party Service Providers working on our behalf:
We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure.
Third Party Product Providers we work in association with:
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party including for a merger, acquisition, divestiture, or similar transaction or as part of any business restructuring or reorganisation.
We may also further transfer data if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to law enforcement. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
Different rules apply depending on the type of Lawful Processing being undertaken, however many of the following individuals’ rights apply whatever the basis of processing:
- The right to be informed how personal data is processed
- The right of access to their personal data
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
The accuracy of personal data is imperative. We aim to keep it updated at all times. The personal data we hold on you is available upon request by contacting You can request that your data is updated and/or deleted at any time, unless Xtravirt can justify that it is retained for legitimate business or legal purpose. When updating your personal data, you may be asked to verify your identity before your request can be actioned.
Links to other websites / from other websites
16 or Under
We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.
What are cookies?
A cookie is a text file containing small amounts of information which a server downloads to your personal computer (PC) or mobile device when you visit a website. The server then sends a cookie back to the originating website each time you subsequently visit it, or if you visit another website which recognises that cookie.
Web pages have no memory. If you are surfing from page to page within a website, you will not be recognised as the same user across pages. Cookies enable your browser to be recognised by the website. So cookies are mainly used to remember the choices you have made – choices such as the language you prefer and the currency you use. They will also make sure you are recognised when you return to a website.
Do all cookies do the same thing?
No, there are different types of cookies and different ways of using them. Cookies can be categorised according to their function, their lifespan and according to who places them on a website.
Our website uses the following types of cookie:
Technical cookies: We try to give our visitors an advanced and user-friendly website that adapts automatically to their needs and wishes. To achieve this, we use technical cookies to show you our website, to make it function correctly. These technical cookies are absolutely necessary for our website to function properly.
Functional cookies: We also use functional cookies to remember your preferences and to help you to use our website efficiently and effectively, for example by remembering your preferred currency and language that you viewed earlier. These functional cookies are not strictly necessary for the functioning of our website, but they add functionality for you and enhance your experience.
Analytics cookies: We use these cookies to gain insight into how our visitors use the website, to find out what works and what doesn’t, to optimise and improve our website and to ensure we continue to be interesting and relevant. The data we gather includes which web pages you have viewed, which referring/exit pages you have entered and left from, which platform type you have used, date and time stamp information and details such as the number of clicks you make on a given page, your mouse movements and scrolling activity, the search words you use and the text you type while using our
website. We also make use of analytics cookies as part of our online advertising campaigns to learn how users interact with our website after they have been shown an online advertisement, which may include advertisements on third-party websites. We will not know who you are, and only obtain anonymous data.
How long do Xtravirt cookies stay active?
The cookies we use have varying lifespans. The maximum lifespan we set on some of them is five years from your last visit to our website. You can erase all cookies from your browser any time you want to.
How can you recognise Xtravirt cookies?
You can find our cookies in your browser settings.
Does Xtravirt use third-party cookies?
Yes, Xtravirt uses the services of trusted and recognised online advertising and marketing companies. Xtravirt may also use third-party providers for analytical purposes. To enable their services, these companies need to place cookies.The providers we use are committed to building consumer awareness and establishing responsible business and data management practices and standards.
When it comes to online advertising and marketing companies, we strive to only work with companies that are members of the Network Advertising Initiative (NAI) and/or the Interactive Advertising Bureau (IAB). Members of NAI and IAB adhere to industry standards and codes of conduct. NAI and IAB members allow you to opt out of the behavioural advertising.
Visit www.networkadvertising.org and www.youronlinechoices.com to identify the NAI members that may have placed an advertising cookie file on your computer. To opt out of an NAI or IAB member’s behavioural advertising programme, simply check the box that corresponds to the company from which you wish to opt out.
In order to control the collection of data for analytical purposes by Google Analytics, you may want to visit the following link: https://tools.google.com/dlpage/gaoptout
Who has access to Xtravirt cookie data?
Only Xtravirt has access to Xtravirt cookies. Cookies placed by third parties can be accessed by these third parties.
How can you manage your cookie preferences?
Using your browser settings in, for example, Internet Explorer, Safari, Firefox or Chrome, you can set which cookies to accept and which to reject. Where you find these settings depends on which browser you use. Use the “Help” function in your browser to locate the settings you need.
If you choose not to accept certain cookies, you may not be able to use some functions on our website. And opting out of an online advertising network does not mean that you will no longer receive or be subject to online advertising or marketing analysis. It means that the network from which you opted out will no longer deliver ads tailored to your web preferences and browsing patterns.
Questions, Complaints and Subject Access Requests (SARs)
Any questions or Subject Access Requests (SARs) should be sent to: GDPR@xtravirt.com.
Review of this Policy
This Policy is regularly reviewed.