Privacy and cookie policy

Strix Group Plc Privacy Policy

Introduction

We respect your privacy and are committed to protecting your personal data. This “policy” will inform you as to how we collect and use your personal data when you visit this website (regardless of where you visit it from). This policy will also tell you about your privacy rights.

This policy is formed of the following sections:

  1. Who we are and important information
  2. The personal data we collect about you
  3. How we collect your personal data
  4. How we use your personal data
  5. Disclosures of your personal data
  6. International transfers of your personal data
  7. Data security
  8. Data retention
  9. Your privacy rights
  10. Glossary

1.Who we are and important information

Who we are

We’re Strix Group Plc of Forrest House, Ronaldsway, Isle of Man, IM9 2RG, info@strix.com, and we’re subject to the laws of the Isle of Man. That’s who we’re talking about when we say “we”, “us” or “our” in this policy. We will be the “controller” of the personal data that we collect from you.

Important information

Purpose of this policy
This policy will inform you as to how we collect and use your personal data when you visit this website (regardless of where you visit it from), including any personal data you may provide through this website when you sign up to our news announcements or fill out a contact form. This policy will also tell you about your privacy rights.

It is important that you read this policy, together with any additional information notice we may provide to you on specific occasions when we are collecting or processing your personal data, so that you are fully aware of how and why we are collecting and using your personal data.

Children
This website is not intended for children and we do not knowingly collect personal data relating to children.

Third party links and third party cookies
This website may include links to third party websites, plug-ins or applications. Clicking on those links may allow third parties to collect and use your personal data. We do not control any third party websites, plug-ins or applications and are not responsible for them. They will have their own privacy policies and terms and, when you click on those links, we encourage you to read such privacy policies and terms.

This website may also include third party cookies. We cannot access these cookies and are not responsible for them. The third parties that place cookies will have their own privacy policies and terms. Again, we encourage you to read such privacy policies and terms.

Our ability to change to this policy
This policy is effective 25 May 2018. We may change this policy by updating this page, so you should check this page from time to time to ensure that you are happy with any changes. Where changes are material, we will take reasonable steps to bring them to your attention.

Changes to your personal data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2.The personal data we collect about you

Personal data is any information about an identified or identifiable individual. It does not include data that is not about an identified or identifiable individual or personal data that has been made anonymous so that the individual is not, or no longer, identifiable (“anonymous data”).

We collect, use, store and transfer different kinds of your personal data, which can be grouped as follows:

  • Identity Datasuch as your first name and last name;
  • Contact Datasuch as your email address;
  • Technical Data” such as your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;
  • Profile Data such as your interests, preferences, feedback and survey responses;
  • Usage Data such as information about how you use this website, our products and our services;
  • Communications Data such as the communications we have with you, whether via this website’s contact form email, post, phone or otherwise.

Aggregated data
We also collect, use and share aggregated data such as statistical or demographic data for various purposes. Aggregated data may be derived from your personal data, but it has been made anonymous data (you are no longer identifiable). For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that you are identifiable, we treat the combined data as personal data which will be used only in accordance with this policy.

If you fail to provide personal data
We have legal and contractual obligationsthat require us to collect and use your personal data and it is necessary for us to collect and use your personal data in order to enter into a contract with you. Where we need to collect personal data for any contractual reasons and you fail to provide that personal data when requested, we may not be able to perform the contract we have, or are trying to enter into, with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with, or have requested from, us, but we will notify you if this is the case at the time.

3.How we collect your personal data

We use different methods to collect your personal data, including through:

  • direct interactions – you may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by email, post, phone or otherwise. This includes personal data you provide when you:
    • register for our RNS email alerts;
    • submit an enquiry to us via our contact page;
  • automated technologies or interactions – as you interact with our website, we may automatically collect your Technical Data. We collect this personal data by using cookies, server logs and other similar technologies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site about aspects of your visit. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. For more information about the cookies we use, please see our Cookie Policy;
  • third parties or publicly available sourceswe may receive your personal data from various third parties and public sources as set out below:
    • Technical Data from the following third parties:
      • analytics, storage, tools and media providers based in and outside the EU;
      • IP tracking service providers based in and outside the EU;i>
      • automated quality control tools based in and outside the EU;
      • automated security and compliance tools based outside the EU;
      • social media and media networks such as Twitter, LinkedIn, Instagram, YouTube and Vimeo based outside the EU;
      • email distribution and survey providers based outside the EU;
    • Identity Data and Contact Data from providers of data feeds and hosting services provided in and outside the EU.

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 we need to perform the contract we are about to enter into, or have entered into, with you;
  • where it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those legitimate interests;
  • where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to collect and use your personal data, and which of the legal bases we rely on to do so. Where such legal bases are our legitimate interests, we have also identified what those legitimate interests are.

You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on legitimate interests. To object please contact gdpr@strix.com.

Note that we may rely on more than one legal basis, depending on the specific purpose for which we are collecting and using your data. Please contact us. if you need further details about the specific legal basis we are relying on to collect and use your personal data where more than one legal basis has been set out below:

i. To manage our relationship with you

This includes:
(a) notifying you about changes to our terms or this policy;
(b) asking you to leave a review or take a survey;
(c) answering any queries you may have.

Type of personal data:
(a) Identity Data;
(b) Contact Data;
(c) Profile Data;
(d) Communications Data.

Lawful basis for processing:
(a) performance of a contract;
(b) comply with a legal obligation;
(c) legitimate interests (being to keep our records updated and to study how customers use our products and services);
(d) to deal with your enquiries.

ii. To administer and protect our business and this website

This includes:
(a) troubleshooting;
(b) data analysis;
(c) testing;
(d) system maintenance;
(e) support;
(f) reporting;
(g) hosting of data.

Type of personal data:
(a) Identity Data;
(b) Contact Data;
(c) Technical Data.

Lawful basis for processing:
(a) legitimate interests (being for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
(b) comply with a legal obligation.

iii. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of personal data:
(a) Identity Data;
(b) Contact Data;
(c) Profile Data;
(d) Usage Data;
(e) Communications Data;
(f) Technical Data.

Lawful basis for processing:
Legitimate interests (being to study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy.

iv. To use data analytics to improve our website, products and services, marketing, customer relationships and experiences

Type of personal data:
(a) Technical Data;
(b) Usage Data.

Lawful basis for processing:
Legitimate interests (being to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.

v. To provide regulatory news via an automated email alert service

Type of personal data:
(a) Identity Data;
(b) Contact Data.

Lawful basis for processing:
Legitimate interests (being to respond to your request to receive RNS announcements.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us here.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5.Disclosures of your personal data

We may have to share your personal data with the third parties set out below for the purposes set out in the table in section 4 above:

  • Internal Third Parties as set out in the glossary;
  • External Third Parties as set out in the glossary;
  • third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy.

We require all third parties that we share your personal data with to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third parties that we share your personal data with to use your personal data for their own purposes and only permit them to use your personal data for specified purposes and in accordance with our instructions.

6.International transfers

We may transfer your personal data outside of the European Economic Area (“EEA”) for one or more of the legal bases set out above.

However, 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries; https://ec.europa.eu/info/law/law-topic/data-prote... and European Commission: EU-US Privacy Shield;
  • third parties based in the US if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.Data security

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 for specified purposes and in accordance with 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.

8.Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

  • Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request from us by contacting us at gdpr@strix.com. In some circumstances you can ask us to delete your data. See your privacy rights – the right to erasure:
    https://www.inforights.im/information-centre/data-...

We may use anonymised data indefinitely, without further notice to you.

9.Making a complaint

If you are unhappy with how we’ve collected or used your information, contact our Data Privacy Officer here:

Address:

The Data Privacy Officer,
Strix Group Plc,
Forrest House,
Ronaldsway,
Isle of Man,
IM9 2RG.

e-mail:

gdpr@strix.com.

You have the right to make a complaint at any time to the Information Commissioner, the Isle of Man Supervisory Authority for data protection issues www.inforights.im. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner, so please contact our Data Privacy Officer in the first instance.

10. Your privacy rights

You have the following rights regarding your personal data:

  • the right to be informed;
  • the right of access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to data portability; and
  • the right to object.

No fee usually required
You will not usually have to pay a fee to exercise your privacy rights. However, we may charge a reasonable fee to cover our administrative costs of providing the information if your request is clearly unfounded, repetitive or excessive. Alternatively, we may be entitled to refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all requests within one month (unless we are entitled to refuse to comply). Occasionally it may 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. Glossary

Lawful basis
“Legitimate interests” means the interests of our business in conducting and managing our business to enable us to give you the best services and products and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our Legitimate Interests. We do not use your personal data for activities where our legitimate interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Performance of contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties” means Strix Group Plc’s affiliates acting as joint controllers and/or processors and who are based in Isle of Man, United Kingdom, China and Hong Kong.

External Third Parties means:

  • digital service providers acting as processors, operating in the EU, who provide a number of services, including but restricted to data feeds, hosting, SSL, data analysis, CRM, video streaming, social media and sharing services;
  • professional advisers acting as processors and/or joint controllers including lawyers, bankers, auditors and insurers based in the Isle of Man, the United Kingdom, China and Hong Kong, who provide consultancy, banking, legal, insurance and accounting services;
  • Isle of Man Customs and Excise, regulators and other authorities who require reporting of processing activities in certain circumstances; and
  • marketing services providers acting as processors including mailing and survey companies operating in and outside of the EU who provide distribution, reporting and analysis of emails and surveys.

Your privacy rights

This section explains your rights regarding your personal data in more detail. The rights are not absolute and each is subject to certain exceptions or qualifications.

Further information about you rights can be obtained from the Information Commissioner www.inforights.im.

The right to be informed – you have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we’re providing you with the information in this policy.

The right of access – you have the right to:

  • confirmation that your personal data is being processed;
  • access your personal data; and
  • certain other information (most of which should be in this policy anyway).

You can request copies of paper and electric records about you that we hold, share or use. To deal with your request, we can request proof of identity and enough information to enable us to locate the information you request.

We can only provide you with your personal data, not anyone else’s personal data. Also, where access would adversely affect another person’s rights, we’re not required to provide this.

The right of access is also not a substitute for disclosure processes in litigation.

Please clearly set out in your access request the information that you are requesting. If this is not clear, we may come back to you to ask you for further information by way of clarification.To exercise your right to request access please contact gdpr@strix.com.

The right to rectification – you have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you.

You may also have the right to have incomplete personal data completed, including by providing a supplementary statement. Whether or not this is appropriate in any particular case depends on the purposes for which your personal data is being processed.

We need to notify any third parties with whom we’ve shared your personal data that you’ve made a rectification request. We’ll take reasonable steps to do this, but this may not always be possible or may involve disproportionate effort.To request rectification please contact gdpr@strix.com.

The right to erasure – you have the right to have your personal data erased, and to prevent processing, where:

  • the personal data is no longer necessary for the purpose it was originally collected or processed;
  • you withdraw consent (where previously provided);
  • you object to the processing and our legitimate interests in being able to keep processing your personal don’t take priority;
  • we’ve been processing your personal data in breach of data protection laws;
  • the personal data has to be erased in order to comply with a legal obligation; or
  • the personal data is processed in relation to offering information society services (i.e. social networking sites and internet forums) to a child.

The right to erasure does not apply where your personal data is processed:

  1. to exercise the right of freedom of expression and information;
  2. to comply with a legal obligation for the performance of a public interest task or exercise of official authority;
  3. for public health purposes in the public interest;
  4. for archiving purposes in the public interest, scientific research historical research or statistical purposes; or
  5. for the exercise or defence of legal claims.

We most commonly refuse requests for the reasons in [4)] and [5)], or where we consider our legitimate interest overrides your objection.

The right to erasure does not therefore provide an absolute ‘right to be forgotten’.To exercise your right to erasure please contact gdpr@strix.com.

Where we’ve disclosed the personal data you want to be erased to third parties, we need to inform them about your erasure request, so they can erase links to, copies or replication of, the personal data in question. We’ll take reasonable steps to do this, but this may not always be possible or may involve disproportionate effort.

It may also be that the recipient is not required to erase your information because one of the exemptions above applies.

The right to restrict – you have the right to restrict the processing of your personal data in the following circumstances:

  • where you contest the accuracy of the personal data, we need to restrict the processing until we’ve verified the accuracy of the personal data;
  • when processing is unlawful and you oppose erasure and request restriction instead;
  • if we no longer need the personal data but you need this to establish, exercise or defend a legal claim;
  • where you’ve objected to the processing in the circumstances detailed in paragraph (a) of [the right to object], and we’re considering whether those interests should take priority.

Where we’ve disclosed your relevant personal data to third parties, we need to inform them about the restriction on the processing of your personal data, so that they don’t continue to process this.

We’ll take reasonable steps to do this, but this may not always be possible or may involve disproportionate effort.

We’ll also let you know if we decide to lift a restriction on processing.To request restriction please contact gdpr@strix.com.

The right to data portability – the right to data portability only applies:

  • to personal data you’ve provided to us (i.e. not any other personal data);
  • where the processing is based on your consent or for the performance of a contract; and
  • when processing is carried out by automated means.

In respect of such personal data, we will provide it to you, or a third party you have chosen, in a structured, commonly used, machine-readable format.

We can refuse your data portability request if the processing does not satisfy the above criteria. Also, if the personal data concerns more than one individual, we may not be able to transfer this to you if to do so would prejudice that person’s rights.

Request data portability

The right to object – you can object to processing in the following circumstances:

  • Legitimate interests, public interest or exercise of official authority You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on legitimate interests or the performance of a task in the public interest or exercise of official authority (including profiling based on these). If we can show compelling legitimate grounds for processing your personal data which override your interests, rights and freedoms, or we need your information to establish, exercise or defend legal claims, we can continue to process it. Otherwise, we must stop using the relevant information.
  • Direct marketing You also can object at any time to your personal data being used for direct marketing purposes (including profiling related to such direct marketing). Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
  • Scientific/historical research and statistics Where we use your information for scientific or historical research purposes or statistical purposes, you can, on grounds relating to your particular situation, object to processing of your personal data. If the processing is necessary for the performance of a task carried out for reasons of public interest, we can continue with this. Otherwise, we must stop using the relevant information. If your objection is accepted, you can request for processing of your relevant information to be restricted or for this to be erased.To do this please contact gdpr@strix.com.

Cookie policy

Introduction

Strix Group Plc (" Strix Group Plc") respects your privacy and is committed to protecting your personal data. This cookie notice will inform you as to how and what cookies are used on this site.

For details about your privacy rights and how the law protects you please see our privacy policy.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site about aspects of your visit. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org.

Use of cookies by this website

The information below details cookie files that may be used within this website.

Anonymous analytics cookies

Each time a user visits our website, external software generates “anonymous analytics cookies” which can tell us whether or not you have visited the site before. Your browser will tell us if you have these cookies and if you do not, we generate new ones.

This allows us to track how many individual users we have and how often they visit the site. We are unable to use these cookies to identify individuals. We use them to gather statistics, for example the number of visits to a page or how long a user stays on the page.

Site performance cookies

This type of cookie remembers your preferences for tools used within our website, so you do not have to reset them each time you visit. Examples include:

• Disclaimers or notifications which require input (accept or decline).
• Filtering options for archives, news, case studies, etc.
• Video/audio streaming speeds that are compatible with your browser.

Third-party cookies

On some pages of our website, other organisations may also set their own anonymous cookies. They do this to track the success of their application, or to customise the application for you. Because of how cookies work, our website cannot access these cookies, nor can the other organisations access the data in cookies we use on our website.

For example, when you submit data through a website form or survey your data may be sent to an external third-party system. This could include a customer relationship management (CRM) system, social media networks or a careers application.