1. Introduction
This privacy policy explains how we collect and use personal data about you when you interact with our websites, subscribe to our content and use our job service.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy information we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
2. Who are we?
This website is provided by Rokman Media. Rokman Media is a trading name of Rokman Group Limited. Rokman Group Limited is a limited company registered in England Wales under company registration number 09097843 and with registered address 71-75 Shelton Street, London, WC2H 9JQ.
For the purpose of the Data Protection Act 1998 (the “Act”), EU General Data Protection Regulation (“GDPR”), PCI-DSS, and European data protection legislation, the data controller is Rokman Group Limited. We control the ways your personal data are collected and the purposes for which your personal data are used by us.
Our Privacy Notice applies to the personal data that Rokman Group collects and uses.
When you interact with our websites, sign up for our newsletters, buy our subscriptions and use our job service we are the “data controller”. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the General Data Protection Regulation 2016 (the “GDPR”) to notify you of the information contained in this privacy policy.
You can contact us at: hello@xpats.io
Third party links
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
3. What kinds of personal data about you do we process?
We may collect, store, and use the following categories of personal data about you:
Categories of Data Include:
- Identity: Name, title, date of birth and gender
- Contact: Billing address, delivery address, email address and telephone numbers
- Technical and usage: Information gathered by the use of cookies in your web browser including information about how you use our website.
- Profile: Your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
- Demographics: Information provided by you about your employer, industry, business and interests
- Your communications with us: Enquiries through our Contact Us pages, our email exchanges with you or records of telephone calls
- Marketing and Communications: Your preferences in receiving marketing from us and our partners and your communication preferences
- Blog comments: Comments posted in response to our content
- Social media: Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback
4. When do we collect your personal data?
- When you visit any of our websites
- When you create an account with us to access our content
- When you subscribe or sign up to one of our publications
- You use your account to buy subscriptions or services
- When you engage with us on our social media pages
- When you provide us with your preferences to receiving marketing from us or from one of our partners
- You send us an email or contact us through our Contact Us pages
- When you post comments to our content
- When you choose to complete a survey we send you or complete a survey on our websites
- When you enter any prize draw or competitions.
5. How and why do we use your personal data?
We aim to provide you with the best news and content in the industry, keeping you up-to-date with the latest news, advice and trends in your sector. To do this we sometimes need to use your personal data in a number of ways depending on your interactions with us and any services you have requested. We will not process your personal data unless we have a legal basis to do so under data protection law. The tables below set this out in detail, showing what we do with your personal data, why we do it, and the legal basis on which we rely.
To provide you with our content or services, such as
- Process and fulfil a request or subscription for an e-newsletter, magazine, or other publication
- To deliver your subscription to you by post or email
- Provide, activate and manage your access to our subscriber/account holder only content
- To process and fulfil a request for an advert to be posted in one of our publications
- To process and fulfil a request for places at our events or seminars or webinars
- To process payments for subscriptions, adverts, award entries, webinars and other products or servicesTo provide customer service and support and to answer any enquiries or concerns
- To notify you of any changes or updates to your accounts or subscriptions
- Assess your eligibility for one of our services or subscriptions
- To update your records and contact details to contact you about your accounts or subscriptions, tracing your whereabouts to contact you about your account or to recover debts
- To run a survey, competition or promotion
Where it is in our legitimate business interests to do so, such as:
- To manage your request or subscription for an e-newsletter, magazine, or other publication
- To develop and improve our content and our services
- To send re-subscribe emails and letters to our previous subscribers, though of course we will not send these to you if you opt out of receiving these types of communications
- For direct marketing communications and related profiling to help us keep our users and subscribers informed about events and services in your relevant industry sector, for example if you sign up to our mailing list, we will keep you up to date about services and events provided by us and our selected partners
- To populate and maintain a database of direct marketing preferences so that we only send you communications which may be of interest to you and so that we don’t send you any communications which you have opted out of receiving
- To respond to requests, enquiries, comments or concerns
- To protect our business and your account from fraud and other illegal activities
- To carry out monitoring and to keep records of our communications with you and our staff
- For market research and analysis and developing statistics
- Subject to appropriate controls or anonymisation, to provide insight of our readers to business partners and our advertisers, for example providing our advertisers with statistics on types of sectors our readers work in
- To assess your eligibility for one of our services or subscriptions
- To update your records and contact details to contact you about your accounts or subscriptions, tracing your whereabouts to contact you about your account or to recover debts
- To use data analytics and website cookies to improve our websites, products, services, marketing, customer relationships and experiences
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising
- For management and audit of our business operations
- To send regularly scheduled email newsletters related to the products or services you are enrolled in
With your consent or explicit consent, such as:
- For some direct marketing, for example where you request promotional emails about one of our events or webinars or awards
- Where you provide your consent for one of our industry partners or advertisers to contact you about their services, events, webinars, whitepapers or HR content
- To administer any of our prize draws, competitions or awards which you enter, we may rely on your consent given at the time of entering
To comply with our legal obligations, such as:
- To process any orders you make using our websites, over the telephone or by post
- To send you communications required by law or which are necessary to inform you about changes to the services we provide you, for example updates to this privacy policy
- To monitor comments posted to our content
6. Do we process any sensitive personal data about you?
We will never ask you to provide sensitive personal data (known as special category personal data in the GDPR) about yourself such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
7. Sharing your data
Trusted third parties
We sometimes share your personal data with trusted third parties such as third-party service providers. We have data processor contracts in place with such third parties which require them to respect the security of your data and to treat it in accordance with data protection legislation.
Examples of the kind of third parties we work with are:
- External payment service providers to process any payments you send us
- Website platform and software providers to assist us with our internet content and services
- Operational companies such as delivery couriers and Royal Mail
- IT companies who support our website and other business systems
- Accountancy companies who administer our accounts
- We may also share your personal data with third parties where required by law or where we have another legitimate interest in doing so.
Our industry partners
On some occasions we may provide your contact details to other companies in our industry for their own purposes, for example so they may contact you about services and events you may be interested in. However, we will only ever provide your details in these circumstances where we have your informed consent.
Subject to appropriate controls or anonymisation, we may also provide limited data to our advertisers to provide them with insight of our readers.
Our business
We may, from time to time, expand, reduce or sell our publications and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, subject to data protection law.
8. Transferring your personal data outside the EEA
We are based in the UK but on occasion may transfer your personal data outside the European Economic Area (“EEA”). For example, where you are based outside the UK and place an order with us, we may need to provide your contact details to a courier outside the EEA.
9. What if you don’t want to share your personal data with us?
If you fail to provide certain information when requested, we may not be able to provide you with our content, products or job services.
10. What should you do if your personal data changes?
You should tell us, so we can update our records. The contact details for this purpose are in this privacy policy.
11. How do we keep your data secure?
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 on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
12. How long do we retain your personal data for?
We retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of providing you with our content, subscriptions and other services and products.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. For example, we may collect demographic information from our readers, anonymise it and provide it to our advertisers.
13. Your rights
Your rights in connection with your personal data
Under certain circumstances, by law 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 information we hold about you corrected.
- 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 exercised your right to object to processing (see below).
- 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. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to another party.
- If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
14. Your right to withdraw consent
In circumstances where we rely on your consent to process personal data about you, you have the right to withdraw your consent for that specific processing at any time.
To withdraw your consent, please contact us at hello@xpats.io
Where you have requested that we provide your personal data to one of our industry partners (for example to enable an industry partner who provided you with a free white paper on HR compliance to market directly to you) or a recruiter or employer, you will need to contact that third party directly to withdraw your consent to that third party processing your personal data.
15. Your right to opt out of direct marketing
There are several ways you can stop direct marketing communications from us:
- Opt out of receiving promotional emails and marketing when you create your account or subscribe to any of our content.
- If you have an account, log in and change your preferences.
- Click the ‘unsubscribe’ link in any email communication we send you. We will then stop sending you any further emails from that particular publication or newsletter.
- Contact us at hello@xpats.io or write to us at Rokman Group Limited, 71-75 Shelton Street, London, WC2H 9JQ, UK.
Please note that you may continue to receive communications for a short period after changing your preferences while we update our systems.
16. Data Protection queries
If you have any questions about this privacy policy or how we handle your personal data, please contact us at hello@xpats.io or write to us at Rokman Group Limited, 71-75 Shelton Street, London, WC2H 9JQ, UK.
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.
17. Changes to this Privacy Policy
We reserve the right to update this privacy policy at any time. We may also notify you in other ways from time to time about the processing of your personal data.
If you have any questions about this Privacy Policy, please contact us: hello@xpats.io.
