Privacy Policy
Introduction
Corient Business Solutions Limited is registered company in England and Wales registered number 7880941 with office at The Techno Centre, Puma Way, Coventry, CV 1 2TT
Corient Business Solutions Limited which is a Data Controller and is registered with the Information Commissioner Office (ICO) under reference ZA095945
Corient Business Solutions Limited (Corient) is strongly committed to protecting personal data. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our website, you’re agreeing to be bound by this Policy. Any questions regarding this Policy and our privacy practices should be sent by email to info@xinowa.com or by writing to Corient Business Solutions Limited, The Techno Centre, Puma Way, Coventry, CV 1 2TT. Alternatively, you can telephone 02476 103333
What is Personal Data
Personal data is any information relating to an identified or identifiable living person. When “you” or “your” are used in this statement, we are referring to the relevant individual who is the subject of the personal data. Corient processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the relevant sections of this statement.
Our processing activities
Potential Clients and Business Contacts
Recruitment Applicants
Our Staff
Suppliers
Individuals who use our Applications
Data Security
We take the security of all the data we hold very seriously. We adhere to internationally recognised security standards and our information security management system relating to client confidential data is independently certified as complying with the requirements of ISO/IEC 27001: 2013. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
Security precautions in place to protect the loss, misuse or alteration of your information
All the data is stored within UK having following minimum standards:
SSAE 16 SOC 1 Type 2 and SOC 2 Type 2 Attestation
PCI Data Compliant
ISO 27001 Compliant
HIPAA and HITECH Compliant
Virtual Private Network through private IP address ranges
256 bit AES Encryption
Deployment of Anti Malware
Multi Factor Authentication
Intrusion detection/Distributed Denial of Service (DDoS) Defense
Regular Penetration Testing
Network Isolation
Virtual Networking
Automated Scans to identify harmful emails
Firewalls and other applicable security standards to detect, investigate and eliminate data threats
Policies and Procedures to monitor usage of data
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 products and / or services to you on our behalf, for example to process payroll, provide bookkeeping services or deliver other specialist services. 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 and not to use it for their own purposes.
We have put in place measures, based upon model contract clauses supplied by the European commission to ensure your personal data is treated by those third parties in a way consistent with and which respects the data protection legislation. The servers powering and facilitating that cloud infrastructure are located in secure data centres in United Kingdom, and personal data may be stored in any one of them. Further details of these providers are mentioned below:
Name
Microsoft Limited
MessageBird
Xero UK Limited
Digital Ocean
Mail Chimp
Role
Azure cloud services, Office 365 and Mail Exchange
Text Messaging
Cloud Accounting Application
Cloud Services
Payroll and Cloud AccountingE Mail Management Software for managing Marketing and Newsletter Services
Text Messaging
Address
Microsoft Campus, Thames Valley Park, Reading, RG6 1WG, UK
New Fetter Lane 8th fl,, 6 New St Square, London EC4A 3AQ
Bank House, 171 Midsummer Blvd, Milton Keynes MK9 1EB
101 Avenue of the Americas (Grand St.)
New York, NY 10013
c/o The Rocket Science Group, LLC, 675 Ponce De Leon Ave NE Suite 5000, Atlanta, GA 30308 USA
WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
As part of the services offered to you, we may send your data outside of the European Economic Area (EEA). Where this is the case, we will take reasonable steps to ensure that your data is protected in the same way as if it was being used in the EEA. For example, where third party suppliers store data in the US, we will ensure that their services fall within the Privacy Shield. https://www.privacyshield.gov
We may use third parties located in other countries to help us run our business. As a result, personal data may be processed outside the countries where we and our clients are located. This includes to countries outside the European Union and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully.
Data Inspection
We strive to be as open as we can be in terms of giving people access to their personal data. A Subject Access Request under the GDPR is your right to request a copy of the information that we hold about you. Such requests must be in writing to the contact details provided in this policy. If we do hold your personal data we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy).
The information we supply will:
confirm that your data is being processed;
verify the lawfulness and the purpose of the processing;
confirm the categories of personal data being processed;
confirm the type of recipient to whom the personal data have been or will be disclosed, and
let you have a copy of the data in an intelligible form.
Please note that you may need to provide identification in order to prove who you are to access your data.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
In the instance that we do not hold information about you we will also confirm this in writing at the earliest opportunity.
Individuals’ rights and how to exercise them
Individuals have certain rights over their personal data and controllers are responsible for fulfilling these rights.
Individuals’ rights may include the right of access to personal data, to rectification of personal data, to erasure of personal data / right to be forgotten, to restrict processing of personal data, to object to processing of personal data, to data portability, the right to withdraw consent at any time (where processing is based on consent) and the right to lodge a complaint with a supervisory authority.
Please see further information about these rights, when they are available and how to exercise them below.
Your right of access to personal data
You have the right to obtain confirmation as to whether we process personal data about you, receive a copy of your personal data held by us as a controller and obtain certain other information about how and why we process your personal data (similar to the information provided in this privacy statement). This right may be exercised by emailing us at info@xinowa.com. We aim to respond to any requests for information promptly, and in any event within the legally required time limits.
Your right to rectification / amendment of personal data
You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete personal data completed.
To update personal data submitted to us, you may email us at info@xinowa.com or, where appropriate, contact us via the relevant website registration page or directly amend the personal details held on relevant websites or applications with which you registered.
When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make updates as appropriate based on your updated information.
Your right to erasure / right to be forgotten
You have the right to obtain deletion of your personal data in the following cases:
the personal data are no longer necessary in relation to the purposes for which they were collected and processed;
our legal grounds for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
our legal grounds for processing is that the processing is necessary for legitimate interests pursued by us or a third party, you object to our processing and we do not have overriding legitimate grounds;
you object to our processing for direct marketing purposes;
your personal data have been unlawfully processed; or
your personal data must be erased to comply with a legal obligation to which we are subject.
To request deletion of your personal data, please email us at info@xinowa.com.
Your right to restrict processing
You have the right to restrict our processing of your personal data in the following cases:
for a period enabling us to verify the accuracy of your personal data where you have contested the accuracy of the personal data;
your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
your personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims; or
for a period enabling us to verify whether the legitimate grounds relied on by us override your interests where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us.
To restrict our processing of your personal data, please email us at info@xinowa.com.
Your right to object to processing
Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis). Where we rely on your consent for our processing of your personal data, to withdraw your consent please email us at info@xinowa.com or, to stop receiving an email from a Corient Marketing list, please click on the unsubscribe link in the relevant email. Please see the relevant “Use of personal data” sections of this privacy statement for further details about our processing of personal data based on consent.
Complaints
Please send an email with the details of your complaint to info@corientbs.com. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred within the EU. The Information Commissioner’s Office (“ICO”) is the UK data protection regulator/supervisory authority. For further information on your rights and how to complain to the ICO, please refer to the ICO website.