Last Updated: 21st May 2018
CyberScore™ is brought to you by XQ Digital Resilience Limited (company registration number: 09184608, registered office: Unit H The Courtyard, Tewkesbury Business Park, Tewkesbury, England, GL20 8GD) (XQ).
This policy (together with the CyberScore™ Terms and Conditions of Service (https://www.xqcyber.com) and (https://www.cyberscore.com) (Terms) and any other documents referred to in the Terms) set out the basis on which any personal data collected from you, that you provide to XQ, or that we receive from other sources, will be processed.
For the purpose of the Data Protection Act 1998 (the Act), XQ is the data controller (i.e. the company who is responsible for, and controls the processing of, your personal data) with registration number ZA216839.
Information XQ May Collect
XQ may collect and process the following data about you:
1.1 Information You Provide
You may give XQ information about you by filling in forms on Cyberscore or by corresponding with XQ by phone, e-mail or otherwise. This includes information you provide when you register to use Cyberscore and subscribe to the service. The information you give XQ may include your (among others) name, address, e-mail address and phone number, financial and credit card information. It is important 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.
1.2 If you fail to provide personal data
Where XQ need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that 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 us but we will notify you if this is the case at the time.
1.3 Information XQ Collects About You
With regard to each of your visits to Cyberscore, XQ may automatically collect the following information:
1.3.1 technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
1.3.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through, and from Cyberscore (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call its customer service number;
1.4 Information XQ Receive From Other Sources
XQ works closely with third parties (including, for example, insurers, business partners, sub-contractors in technical, payment and delivery service, advertising networks, analytics providers, search information providers and credit reference agencies) and may receive information about you from them which XQ will add to the information it already holds about you.
2. Information About Other Individuals
If you give XQ information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can give consent on his/her behalf to the processing of his or her personal data and receive on his/her behalf any data protection notices.
XQ may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.
4. Credit Checking
To enable XQ to make credit decisions about you and for fraud prevention and money laundering purposes, XQ may search the files of credit reference and fraud prevention agencies (who will record the search). XQ may disclose information about how you conduct your account to such agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked. Other credit grantors may use this information to make credit decisions about you and the people with whom you are financially associated, as well as for fraud prevention, debtor tracing and money laundering purposes.
5. How Your Information May Be Used
XQ use information held about you in the following ways:
5.1 Information You Provide
XQ will use this information to:
5.1.1 carry out its obligations arising from any contracts entered into between you and XQ and to provide you with the information, products and services that you request from time to time;
5.1.2 provide you with information about other goods and services XQ offer that are similar to those that you have already purchased or enquired about;
5.1.3 notify you about changes to Cyberscore;
5.1.4 ensure that content from Cyberscore is presented in the most effective manner for you and for your computer; and
5.1.5 if you have provided express permission, pass your details on to third parties for marketing purposes.
5.2 Information XQ Collects About You
XQ will use this information:
5.2.1 to administer Cyberscore and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
5.2.2 to improve Cyberscore to ensure that content is presented in the most effective manner for you and for your computer;
5.2.3 to allow you to participate in interactive features of its service, when you choose to do so;
5.2.4 as part of its efforts to keep Cyberscore safe and secure;
5.2.5 to measure or understand the effectiveness of advertising; and
5.2.6 to make suggestions and recommendations to you and other users of Cyberscore about goods or services that may interest you or them.
5.3 Information XQ Receives From Other Sources
We may receive personal data about you from third parties like Google (analytics provider) which is based outside the EU.
6. Purposes for which we use your personal data
We have set out below, in table format, a description of all the ways we plan to use your personal data, and which legal bases we rely on to do so.
Purpose / Activity
Lawful basis for processing
To register you as a new client
Performance of a contract with you
Manage payments, fees or charges
Performance of a contract with you and necessary to our legitimate interests to recover debt from you
Performance of a contract with you and necessary to comply with a legal obligation
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Necessary for our legitimate interests (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)
Necessary to comply with a legal obligation
To use data analytics to improve our website, services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you
Necessary for our legitimate interests (to develop our professional services and grow our business)
To send you marketing
Consent or legitimate interests
7. Disclosure Of Your Information
7.1 XQ may share your personal information with any member of its group, which means its subsidiaries, its ultimate holding company and such holding company’s subsidiaries, as defined in section 1159 of the UK Companies Act 2006
7.2 XQ may share your information with selected third parties including:
7.2.1 business partners, suppliers and sub-contractors for the performance of any contract XQ enters into with them or you;
7.2.2 analytics and search engine providers that assist XQ in the improvement and optimisation of Cyberscore; and
7.2.3 credit reference agencies for the purpose of assessing your credit score.
7.3 XQ may disclose your personal information to third parties:
7.3.1 in the event that XQ sell or buy any business or assets, in which case XQ may disclose your personal data to the prospective seller or buyer of such business or assets;
7.3.2 if all, or substantially all, of its assets are acquired by a third party, in which case personal data held by XQ about its customers will be one of the transferred assets; and
7.3.3 if XQ are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the Terms and other agreements; or to protect the rights, property, or safety of its customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7.4 XQ require all third parties to respect the security of your personal data and to treat it in accordance with the law. XQ 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.
8.1.1 recognise you whenever you visit Cyberscore (this speeds up your access to the site as you do not have to log on each time);
8.1.2 obtain information about your preferences, online movements and use of the internet;
8.1.3 carry out research and statistical analysis to help improve content, services and to help XQ better understand its customer requirements and interests;
8.1.4 target its marketing and advertising campaigns more effectively; and
8.1.5 make your online experience more efficient and enjoyable.
8.5 If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of Cyberscore. For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org
9. Where XQ Stores Your Personal Data
9.2 All information you provide to XQ is stored on its secure servers. Where XQ has given you (or where you have chosen) a password which enables you to access certain parts of Cyberscore, you are responsible for keeping this password confidential. XQ asks you not to share a password with anyone.
XQ 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. However, the transmission of information via the internet is not completely secure. XQ 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.
11. Third Party Links
Cyberscore may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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 the 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 legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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.
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 your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Complain you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.