IRJJJR Holdings (“IRJJJR”, “we”, “us”, “our”), a company incorporated under the laws of the United Kingdom, provides the exlink Platform ("the Platform"), a software as a service (SaaS) platform for procurement and administration of expert calls and related services. It also provides a website - www.exlink.co.uk
A separate agreement governs delivery, access and use of the exlink platform (the “Agreement”), including the processing of any data and other information that the customer or expert network, including individuals granted access to the Platform by customers or expert networks (“Users”), submits to and stores within the Platform in connection with the use of the Platform (“Service Data”).
In general, the Customer and/or the Expert Network is the controller of Service Data. IRJJJR is the data processor of Service Data and will only process it in accordance with the data controller’s written instructions, the relevant data processing agreement and applicable law.
In general, IRJJJR is the controller of Other Information (as defined in Section 2 of this policy).
We will receive and collect information and personal data from you and from third parties when you are using the Services.
1. SERVICE DATA
1.1. Customers, Expert Networks or Users may submit Service Data when using the Platform, and IRJJJR will process such data on behalf of the Customer or the Expert Network.
1.2. The categories of personal data that are submitted may include, but are not limited to:
(a) Any messages, files or other content submitted through the Platform, such as information regarding an expert, relevant expertise, employment history and name.
1. OTHER INFORMATION
In addition to Service Data, IRJJJR collects and/or receives other information, data and personal data (“Other Information”) in a variety of ways during the course of providing the Services.
The different types of Other Information are listed below:
1.1. USER ACCOUNT INFORMATION
1.1.1. IRJJJR may collect and/or receive Other Information when you set up an account or invite a new User to join the Platform.
1.1.2. The categories of personal data that are collected and/or received when setting up an account or inviting a User to the Platform may include:
(a) Name, email address, telephone number, title, and employer (company name).
(b) Additional data if you hold a Platform account relating to a customer (client): location, business unit, and title.
1.2. ADDITIONAL CONTACT INFORMATION
1.2.1. You may choose to share your personal data with us if you contact us. We might also receive Other Information when submitted to the Site if you apply for a job, request support, interact with our social media accounts or otherwise communicate with IRJJJR.
1.2.2. The categories of personal data that are collected when you contact us may include, but are not limited to:
(c) Name, email address, telephone number, title, employer, postal address, CV, and images.
1.3. USAGE INFORMATION & COOKIE INFORMATION
1.3.1. When you are using the Services, IRJJJR may collect Other Information to help us develop the Services and improve your user experience.
1.3.2. The categories of personal data that are collected when you use the Services may include, but are not limited to:
(a) Device information: IRJJJR collects information about the device you use to access the Services, including type of device and what operating system is used.
(c) Log data: Our servers will automatically collect information when you access the Services and record it into log files. This log data may include you Internet Protocol (IP) address, browser type and settings, the date and time the Services were used, information about browser configuration and cookie data.
(d) How you use the Platform: We will collect information on how you use the Platform, such as information regarding how often you visit the Platform, which pages you visit on the Platform, links clicked and mouse movements.
(e) Site Analytics: The Site uses Google Analytics as a web statistics tool, however, not to track individual users. For further information on how Google Analytics collects and uses information on our behalf and the right to use such cookies, please refer to the Google Analytics products and services privacy statement.
1. HOW WE USE INFORMATION
1.1. Service Data will be used by IRJJJR in accordance with customer’s or expert network’s instructions, including any applicable terms in the Agreement. The customer and the expert network are separate and independent controllers of the Service Data, and IRJJJR is a processor.
1.2. Other Information (as listed in Section 2.) is used in IRJJJR’s legitimate interest to provide Services. More specifically, IRJJJR uses Other Information:
(a) To provide, update, maintain and protect our Services.
(b) To prevent, investigate or address security or technical issues.
(c) To analyze and monitor usage of the Services.
(d) To provide customer support.
(e) To ensure that content is presented in the most effective manner for you and for your device.
(f) To communicate with Users around tech, security and admin related matters
(g) For billing, account management and other administrative matters.
1. HOW LONG WE KEEP INFORMATION FOR
1.1. IRJJJR will retain Service Data in accordance with Customer’s or Expert Network’s instructions, including any applicable terms in the Agreement, and as required by applicable law.
1. IRJJJR may transfer Personal Data to sub-processors in countries located outside the EU/EEA
2. When doing so we are committed to protect your data and comply with applicable data protection laws. We deploy one of the following safeguards if IRJJJR transfers Personal Data originating from the EU/EEA area to other countries not deemed adequate under applicable data protection law:
(a) EU-U.S. Privacy Shield Framework
(b) European Union Model Clauses (Standard Contractual Clauses)
1. YOUR RIGHTS
1.1. You have a right to access your personal data. Therefore, you may request a transcript of records if you would like to know and verify your personal data stored and processed by us. The request must be made in writing, including a verification of you, and sent to the address listed in Section 11. “Contact Information”.
1.2. We take all reasonable steps to ensure that your personal data is correct and up-to-date. You have the right to correct inaccurate or incomplete information about yourself. If you believe that your personal data stored by us is incorrect, please notify us and provide us with the correct data.
1.3. You have the right to request the deletion of your personal data insofar as this personal data is no longer necessary for the purpose it was collected (“right to be forgotten”). However, certain legal obligations prevent us from immediately deleting all your data, such as obligations in accounting laws, tax laws and anti-money laundering laws. Data that must be preserved for legal reasons will be blocked from use for any other purposes than meeting such legal requirements.
1.4. You have the right to object to our processing of your personal data. The effect may be that you are no longer able to use the Platform. If you object, we will stop the processing of your personal data.
1.5. You have a right to data portability. In case you want to utilize such right, please contact us by using the information below.
1.6. If you have any inquiries regarding our processing of your personal data, please contact us. If you are displeased with our processing of personal data, you may file a complaint to the Information Commissioner's Office, https://ico.org.uk/, the equivalent authority in the EU-member state where you live, or with the relevant authority in your country of residence outside of the EU, if any.
1.1. We are using adequate technical and organizational security measures to ensure that your personal data is not misused, lost, or unlawfully accessed. We only give access to your personal data to those employees who require it to provide our services, including the Platform.
1. UPDATES TO THIS POLICY