CXC Privacy Policy
Our Privacy Policy may vary based on the CXC region. Click any link below to be transferred to the policy of the appropriate section.
Australia and New Zealand Privacy Policy
1.0 SCOPE
This privacy policy (“Policy”) applies to Global Contractor Management Solutions Pty Ltd (“GCMS”) and any entity owned or controlled by it (“Related Entity”) in relation to GCMS’ and its Related Entities’ (together “CXC” or “we”) operations in Australia and New Zealand.
At CXC we are committed to ensuring the privacy of your personal information.
CXC respects and upholds your rights to privacy protection under the relevant Australian and New Zealand privacy legislation. Therefore, we are committed to complying with the Australian Privacy Principles (“APPs”) under the Privacy Act 1988 (Cth) and the New Zealand Information Privacy Principles (“IPPs”) under the Privacy Act 2020 (collectively “Privacy Acts”).
CXC provides large-scale contingent workforce management services including on-demand talent sourcing, recruitment process outsourcing, employee of record (“EoR”)/agent of record (“AoR”) services, contractor management and payroll services (collectively “Services”)to facilitate the recruitment of employees and the management of non-permanent workers for CXC company clients.
CXC has four main groups of stakeholders/clients from whom and for whom we collect, use and disclose personal information: (i) individuals including employees and contractors for our Client Companies (“Individual Clients”), (ii) companies that engage us for one or more of our Services (“Client Companies”), (iii) representatives of and contacts for our Client Companies, Agencies and other suppliers (“Representatives”) and (iv) recruitment agencies and other talent sourcing suppliers (“Agencies”).
For Individual Clients we provide payroll and administration services.
For Client Companies, we provide you with our Services including, where relevant, to enable you to engage with our Individual Clients and to work with Agencies in order to do so.
For Representatives, we liaise with you in order to provide our Services to our individual Clients, and Client Companies and/or, as applicable, receive Agency and other supplier services and products
For visitors and users of our website who are not otherwise Individual Clients or Representatives (“Visitors”), which website is available at https://www.cxcglobal.com/ (“Website”) please see Section 11 below.
For all Individual Clients, Representatives and Visitors, this Policy explains how CXC handles your personal information in accordance with the Privacy Acts.
2.0 PROVIDING US WITH YOUR PERSONAL INFORMATION
You do not have to provide us with your personal information. However, if you are an Individual Client or Representative and choose not to provide us with your personal information or allow us to collect personal information about you, we will be unable to carry out our functions or activities and provide you or our Client Companies (as relevant) with our relevant Services.
3.0 OBLIGATIONS ON CLIENT COMPANIES
If you engage some or all of our Services, as a client company, your privacy policy or privacy notice should explain which of our Services you have engaged in order to assist our Individual Clients determine which of the subsections of 4.2.1 to 4.2.4 apply to them. Also, before providing us with the personal information of any individual (including Individual Clients) you must have notified them of such disclosure and this Policy and, in addition, where any sensitive information is disclosed obtain their consent to our collection, use and disclosure of their sensitive information in accordance with this Policy.
4.0 TYPES OF PERSONAL INFORMATION WE COLLECT
The types of personal information we collect about you depends on whether you are an Individual Client, Representative or Visitor.
4.1 FOR REPRESENTATIVES
If you are a Representative for a Client Company, Agency or other company supplier (in each case whether prospective or existing), we collect the following personal information about you:
general contact information including contact name, phone number, email address; and
(for contractors) company director/sole trader, information available on a bankruptcy register report including an individual’s name, suburb or full address, date of birth and bankruptcy history/status.
4.2 FOR INDIDVIDUAL CLIENTS
For Individual Clients the personal information we collect from you depends on which of our Services you and/or your prospective or current “host-company” (i.e. where you currently or will work and our Client Company) is engaging us for. In many cases, your current or prospective host-company (i.e. our Client Company) may be utilising several of our Services.
To determine what personal information we are collecting from you, please consult the relevant privacy policy or privacy notice of your current or prospective host-company to ensure you understand which of the Sections from 4.2.1 to 4.2.4 apply to you (based on the extent of your host-company’s relationship with us).
4.2.1 For our EoR/AoR and contractor management outsourcing Services
If your host-company is utilising our EoR/AoR or contractor management outsourcing Service, the personal information we collect about will be across two stages: (i) the ‘onboarding’ stage and (ii) the ‘ongoing employment’ stage.
‘Onboarding’ stage
Once the Client Company has delegated management of its employers and/or contractors to us, we will onboard you to CXC and collect the following personal information about you at that time (“Onboarding PI”):
Your general contact information including your name, mailing address, email address, telephone number
Your financial details including bank account details and superannuation details
Your relevant Tax Identification Number (TIN), used for your country’s identification of you for tax administrative purposes for example your Tax File Number in Australia and IRD Number in New Zealand)
Identification information and documents including, on a temporary basis, a copy of your photo ID and a short video of you in a virtual or online meeting in which we seek to verify your identity
Information relating to your right to work in Australia and/or New Zealand including (as relevant): passport information and visa details
Results of relevant fitness to work and functional assessments including medical assessments and criminal record, education, reference, media checks and bankruptcy checks
(If you are a contractor and sole trader): your company financial details, business number (ABN, NZBN), corporate financial information and insurance details
‘Ongoing employment’ stage
Once you have been you have been onboarded to CXC, in addition to the Onboarding PI we hold about you, we collect the following personal information about you:
Timesheets
Payslips including taxation details
Salary information
Trade union membership
Contractual material including: contract extensions, termination letters, employment letters
Performance feedback from your host-company
Details of any workplace injury claim(s)
Where relevant, your unique student identifier (USI)
Where relevant to your employment, details of any relevant licence or registration you may have (including high risk work licence, white card or spotter certification, forklift licence, etc.)
4.2.2 For our managed service provider (MSP), on-demand talent sourcing, direct sourcing and Recruitment process outsourcing (RPO) services
If your host-company/our Client Company is utilising any of our MSP, on-demand talent sourcing, direct sourcing or RPO services, the personal information about you we collect depends on the status/progress of your application for an position at that Client Company, whether you are at (i) the ‘candidate’ stage and (ii) the ‘onboarding’ stage.
Candidate stage
If you apply for a position at Client Company via CXC or any of our Services, either as an employee or contractor, we collect the following personal information about you (“Candidate PI”):
Your general contact information including: your name, mailing address, email address, telephone number;
Your career history;
Details of any competency tests;
For specific roles, evidence of relevant qualifications such as drivers licence, heavy vehicle licence, white card or spotter certification
Onboarding stage
If you are successful in your application for a position at the Client Company and begin an ongoing engagement as an employee or contractor with the Client Company, you may be onboarded by us or the Client Company.
If you are onboarded by the Client Company, please consult the Client Company’s privacy policy or notice about how your personal information is collected, used and disclosed by them.
If you are onboarded by us, in addition to the Candidate PI collected from you, we will collect the Onboarding PI from you (as detailed above in 4.2.1).
4.2.3 For our global payroll Service
If your host-company/our Client Company is utilising our global payroll Services, where you are not onboarded by CXC for one or more of our other Services, we will separately collect the following personal information about you:
Your general contact information including your name, mailing address, email address, telephone number
Financial information including banking details
Salary information
Your Tax File Number
Trade union membership
Timesheets
Payslips
PAYG withholding tax
Contractual material including: contract extensions, termination letters, employment letters
If you are a sole trader: company financial details, ABN and corporate financial information
4.2.4 For our Workforce Exchange (WEX) or Out of Office Services
If you choose to sign up for our Out of Office Services, we collect the following personal information about you:
Your general contact information including your name, mailing address, email address, telephone number
Career history and employment information
If you choose to sign up to our Workforce Exchange services, having previously been onboarded or placed by CXC at a Client Company, we will not collect any additional information from you other than as noted above from 4.2.1 – 4.2.3, whichever applies to you, but we will use personal information about you for the purposes of the WEX Service and to action any requests from Client Companies for potential employment.
5.0 TYPES OF SENSITIVE INFORMAITON WE COLLECT (FOR AUSTRALIA ONLY)
For those of you located in Australia at the time of our collection of personal information about you (as specified in Section 4.0 of this Policy), we note the following personal information noted above as collected about you is also sensitive information:
For Individual Clients:
Your driver’s licence or other photo identification (where collected)
Your identification (ID) documents and information where a copy is collected in the course of verifying your identity and/or your right to work in Australia or New Zealand, such as a copy of a passport, visa, international ID documents and/or photo ID
On a temporary basis only, a short video of part of your attendance at a virtual or online meeting in order to verify your identity
Results of your fitness to work assessments including medical assessments and criminal record checks
Your membership of a trade union
Details of any health information such as related to a workplace injury claim
Your TFN
For the purposes of this Policy, all references to personal information will include this sensitive information except where expressly otherwise noted.
By using any of our Services, commencing or continuing your engagement with us or a Client Company or providing us with any of your sensitive information, you consent to us collecting, using and disclosing your sensitive information as noted above in accordance with this Policy.
6.0 HOW WE COLLECT PERSONAL INFORMATION ABOUT YOU
6.1 FOR INDIVIDUAL CLIENTS
From our Client Company: For many of our Services, including where your host-company/our Client Company is using our global payroll Services and/or EoR, AoR or contractor management outsourcing Services (i.e. has outsourced the management of their employees and/or contractors to us), our Client Company will provide us with personal information about you to enable us to provide the Services to them and you. The extent of personal information about you the Client Company provides to us depends on the specific arrangements between us and our Client Company, but is limited to personal information that our Client Company originally collected about you.
To perform some of our Services we may require further personal information about you (in addition to personal information provided to us by our Client Company) which we will collect about you (as outlined below).
Directly from you: For some of our Services, including MSP, on-demand sourcing, direct sourcing and RPO Services, we will collect personal information directly from you when you submit (i.e. your personal information included in) (i) your application or resume through employment portals such as LiveHire that we manage on behalf of our Client Company; and/or (ii) information you provide via the ‘MyCXC’ portal.
6.2 FOR REPRESENTATIVES
From our Client Company: If you are a Representative of a Client Company, Agency or other supplier company (existing or prospective) that we work with, we collect personal information about you from your employer when it provides your information to CXC in order for them to engage any of our Services or to receive any of your employer’s services or products.
7.0 USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
We use personal information about you to perform the Services or other business activities, which uses include:
To check your ID documents and/or verify your identity including in an online or virtual meeting
Receipt of services from an Agency or other supplier
Facilitating the provision of our Services (described above at 4.2) to you and/or a Client Company by us
Where your employer is a Client Company, Agency or other company supplier (or are potential clients or suppliers) and you are a Representative, to liaise with you on behalf of them
Considering you for role at or for CXC (whether as an employee or a contractor) and, if successful, carrying out onboarding and ongoing management of you
Managing any complaint, investigation, process or inquiry in which you are involved
Managing any insurance claim or proposal that requires disclosure of your personal information, including injury and workers compensation claims
Direct marketing of our Services to you as a Representative of a Client Company (or a prospective Client Company). Note: If you no longer wish to receive direct marketing from us, please use the link labeled ‘Unsubscribe’ at the bottom of these emails. Alternatively you may request not to receive direct marketing communications by contacting us using the details in the ‘How to contact us about privacy’ Section below
As required or permitted by law
We will disclose your personal information, for the purposes noted above and as required or permitted by law, to:
Potential employers, including our Client Companies, which may wish to engage you as an Individual Contractor services as an employee, contractor or temporary resource
Organisations that conduct competency or psychometric tests
Referees
Worker’s compensation body(s) and/or our insurers to process injury and worker compensation claims
The ATO and other government or regulatory bodies including to remit tax and pay your superannuation contributions
Suppliers of services to us, including professional advisors, Agencies and other suppliers
Our related entities in the worldwide CXC group for group administration and/or to enable the provision of our Services globally
Persons authorised to act on your behalf
Depending on the circumstances, to the Australian Federal Police (and other similar bodies) to verify whether you have a criminal record
Third party service providers to assist us to undertake identity verification, ID checks and/or to provide our Services including direct marketing of our Services to Representatives, including by email.
8.0 CROSS-BORDER DISCLOSURE OF YOUR PERSONAL INFORMATION
In providing our Services and for the purposes noted above, CXC may disclose your personal information to a recipient outside of Australia or New Zealand (“overseas recipient”), including to overseas facilities or contractors located in the Philippines to process or back-up our information or to provide certain services to us
CXC will also disclose your personal information to other entities in the CXC group located in the Philippines, Australia and New Zealand, in order to assist us to provide our Services and for the purposes noted above.
9.0 SECURITY OF YOUR PERSONAL INFORMATION
We will take reasonable steps to protect your personal information that we hold from misuse, interference, and loss as well as unauthorised access, modification, or disclosure.
10.0 KEEPING YOUR PERSONAL INFORMATION UP TO DATE
To assist us with keeping your personal information accurate, up to date, complete and relevant, please use the ‘MyCXC’ portal to update your information (where available to you) or contact us using the details in the “How to contact us about privacy” Section below if any of your personal information changes or if you believe that the personal information we have about you is not accurate, up to date, complete or relevant. We may also contact you from time to time to check the information is still correct.
For most Individual Clients you may update your personal information at any time by logging into the ‘MyCXC’ portal. You will find options on the portal for editing your information that you have submitted. Alternately, please contact our Customer Service Team via the contact us page in the portal. If this is not applicable (i.e. if you do not have access to the portal or the Customer Service Team), please contact us using the details in the “How to contact us about privacy” Section below to seek to correct your personal information.
11.0 WEBSITE & VISITORS
When you browse through the pages of the Website as a Visitor and read or download information, we may collect or note details about your visit such as:
Your server / Internet Protocol (IP) address
Your operating system, top level domain name and the type of web browser you use
The date, time, and duration of your visit to the Website
Whether you have visited the Website previously and what content you viewed.
The information we may collect relates to your server or PC rather than you (except where you separately provide personal information to CXC). The information we collect will be used within CXC to help us improve the Website by tailoring it to better suit your needs and to provide quicker and more effective access to the various components of the Website. We may disclose this information to other persons for these purposes or for related purposes, including to information technology companies who assist us in constructing, designing, and maintaining the Website.
We will also collect your personal information including name, work email address, company name and phone number if you request information about CXC using the Website or, if you request, by email or if you call us with a comment or query. We will use your details:
To send you the information you have requested
To answer your comment or query
To monitor our responses to you
For our internal sales and marketing analysis
If necessary, we may also contact you to follow up on your request or to provide you with further information which may be of interest to you. Please note that once you, the Client Company or your employer are engaged with us for any of our Services or as a supplier, then you will be an Individual Client or Representative and, in which case, please refer to the other Sections of this Policy for the personal information we collect about you and how we use and disclose it.
12.0 ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION
You have the right to access and/or correct any personal information we hold about you. To do so you must provide evidence of your identify which must clearly show that you are the person whose personal information is being requested or is being sought to be corrected.
As noted above, for most Individual Clients you may update or correct and access your personal information at any time by logging into the ‘MyCXC’ portal. You will find options on the portal for editing the information you have submitted. Alternately, please contact our Customer Service Team via the contact us page in the portal. If this is not applicable (i.e. if you do not have access to the portal) or if there is personal information about you that you cannot access or correct via the ‘MyCXC’ portal, please contact us using the details in the “How to contact us about privacy” Section below to access or correct your personal information.
Otherwise, in order to seek to access or correct any personal information we hold about you, please contact us using the details in the “How to contact Us about privacy” Section below. We will respond to your request as soon as is reasonably practicable and, in any case, not later than 20 business days. We will correct or provide access to your personal information (as the case may be) unless an exception to access or correction applies or we are otherwise permitted or required by law not to so correct or provide such access. However, we will advise you of any exception that applies within 20 business days of your request. We may charge a reasonable fee for providing any access but we will confirm the amount with you before processing your request.
13.0 IF YOU HAVE ANY CONCERNS OR WISH TO MAKE A COMPLAINT
If you have any concerns about how we handle your personal information, believe we have breached any of the relevant Privacy Acts, wish to make a complaint or if you need further information, please contact us using the details in the “How to contact Us About privacy” Section below. You will need to provide us with sufficient detail regarding your complaint and any supporting evidence. We will investigate the issue and determine the steps to be taken to resolve the complaint. We will notify you in writing if we require any additional information and also of the outcome of our investigation.
If you are not happy with the outcome of our investigation, you may complain to:
In Australia
The Office of the Australian Information Commissioner by way of their website www.oaic.gov.au or phone hotline 1300 363 992.
In New Zealand
The Office of the Privacy Commissioner by way of their website www.privacy.org.nz/your-rights/making-a-complaint-to-the-privacy-commissioner/.
14.0 HOW TO CONTACT US ABOUT PRIVACY
You can contact us via the relevant country contact details immediately below if you:
Wish to access, update, or correct your personal information (where such is not available via to you the MyCXC portal)
Require further information about how we handle personal information
Wish to make a complaint or have a concern in relation to our handling of your personal information
Wish to request not to receive direct marketing communications
For contractors and those engaged directly by a Client Company, we also recommend you refer their privacy policy if you have any questions relating to their handling of your personal information
Australia
The Privacy Officer
CXC
PO Box 7217
Warringah Mall Shopping Centre, Brookvale NSW 2100
Email: compliance@cxcglobal.com.au
New Zealand
PWC Tower
Level 17
15 Customs Street West
Auckland 1010, New Zealand
Email: compliance@cxcglobal.com.au
15.0 DEVELOPMENT AND REVIEW
This policy will be reviewed from time to time to ensure it remains relevant, compliant with current legislation and appropriate to the collection, use and/or disclosure of your personal information by CXC. As a result, we may update this Policy to reflect changes in how we handle personal information or to reflect any changes to the Privacy Acts. If we make any changes to this Policy, we will notify this by updating the date of this Policy and posting it on our Website with a notice on our Website with an alert that the Policy has been updated.
Where there are significant revisions to our processing of your personal information we will also notify you directly of the changes via the MyCXC portal, by email or by text/SMS.
Any modifications to this Policy will be effective on our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services, provision of any further personal information or your continued interaction with us after the effective date of the modified Policy indicates your acknowledgment of the modified Policy and, if in Australia, your consent to any additional, new or changed collection, use or disclosure of any sensitive information referred to in that modified Policy notice.
Policy last updated [August] 2024.
16.0 THIS POLICY WAS APPROVED BY
The Principal Governing Body of CXC has reviewed and approved this statement – December 2024
17.0 QUALITY CONTROL
Asia Privacy Policy
This privacy policy applies to Global Contractor Management Solutions Pty Ltd (“GCMS”) and any entity owned or controlled by it (“Related Entity”) in relation to GCMS’ and its Related Entities’ (together “CXC Global” or “we”) operations in APAC. CXC Global respects and upholds your rights to privacy protection under the Australian Privacy Principles (“APPs”) contained in the Privacy Act 1988 (Cth) (“Privacy Act”). At CXC Global we are committed to ensuring the privacy of your personal information. This privacy policy explains how CXC Global handles personal information and complies with the requirements of the Privacy Act.
COLLECTION OF PERSONAL INFORMATION
We only collect and hold personal information about you that is reasonably necessary for one or more of our business functions or activities, which may include:
- facilitating services to or by us, where you or your organisation is a client or service provider or potential client or service provider
- managing any complaint, investigation or inquiry in which you are involved
- managing any insurance claim or proposal that requires disclosure of your personal or sensitive information
- direct marketing of our services to you.
If you choose not to provide us with personal information, we may be unable to do such things.
Whenever it is reasonable and practicable to do so, we only collect your personal information directly from you. We may collect personal information about you when you deal with us by telephone, letter, fax, e-mail or visit our website. There may be occasions when we obtain personal information about you from a third party, where it is unreasonable and impracticable to collect the information directly from you (e.g. where we collect information from your nominated referees, when receiving the results of a psychological or competency test or obtain performance feedback about your work). We will generally seek your prior consent to such collection and will take such steps as are reasonable in the circumstances to notify you that we have collected personal information or to otherwise ensure that you are aware of the circumstances of that collection.
Generally, the type of personal information we collect about you is the information included in your application, résumé or information that we record through the ‘MyCXC’ portal. For example, your name, mailing address, telephone number, e-mail address, career history, details of any competency tests or other information relating to your career. In some circumstances, we may also collect sensitive information about you such as information about your membership of a professional or trade association or trade union, your health (including any disability), your racial or ethnic origin or any criminal record that you may have. We will only collect sensitive information about you with your consent and if the information is reasonably necessary for one or more of our functions or activities, unless an exception applies under the APPs.
Because of the nature of our business it is impracticable for us to deal with individuals on an anonymous basis or through the use of a pseudonym.
If we receive personal information that we did not solicit, where we determine that we could not have collected that information in accordance with the APPs, we will, where lawful to do so, destroy the information or ensure the information is de-identified.
USE AND DISCLOSURE OF PERSONAL INFORMATION
We may use and disclose your personal information that we hold for the particular purposes for which it was collected. We will not use or disclose any personal information about you for any other purpose without your consent, unless an exception applies under the APPs. We may disclose your personal information to:
- potential employers
- clients who may wish to engage your services as a contractor or temporary resource
- organisations that conduct competency or psychometric tests
- referees
- a worker’s compensation body
- our insurers
- the ATO and other government or regulatory bodies
- suppliers of services to us
- our related entities
- a person authorised to act on your behalf
- depending on the circumstances, to the Australian Federal Police to verify whether you have a criminal record.
We may use or disclose personal information about an individual for direct marketing of our products or services, including by email. We will only use personal information for direct marketing where we have collected the information directly from you, and have made you aware that the information may be used for such purpose, or you have consented to use of the information for such purpose. However, individuals may request not to receive direct marketing communications by contacting us.
CROSS-BORDER DISCLOSURE OF PERSONAL INFORMATION
In providing our services, CXC Global, its service providers or clients may disclose personal information to a person outside of Australia (“overseas recipient”), including to overseas facilities or contractors to process or back-up our information or to provide certain services to us. CXC Global may disclose your personal information to other entities in the global CXC group, including entities located in the Philippines and New Zealand. Unless you provide your informed consent to the disclosure or another exception applies under the APPs, where your personal information is disclosed to an overseas recipient, we will take such steps as are reasonable in the circumstances to ensure the overseas recipient does not breach the APPs in relation to that information. Where an exception applies, we may disclose your information to an overseas recipient in accordance with the terms of the relevant exception.
KEEPING YOUR E-INFORMATION UP-TO-DATE
We will take such steps as are reasonable to ensure that personal information we collect is accurate, up to date and complete and that personal information we use or disclose is accurate, up to date, complete and relevant. To assist us with this, you should contact us if any of your personal information changes or if you believe that the personal information we have is not accurate, up to date, complete or relevant. We may also contact you from time-to-time to check the information is still correct. You may update your personal information at any time, to do so simply log into the ‘MyCXC’ portal, and you will find options for editing the information you have submitted. Alternately, please contact us at privacy@cxcglobal.com
ACCESS AND CORRECTION OF PERSONAL INFORMATION
You can gain access to the personal information we hold about you by contacting us. We will give full access to personal information, within a reasonable period after a request is made, unless an exception to access applies under the APPs. We will advise you of any exception that applies. We may charge a reasonable fee for providing access. Where we hold information that you are entitled to access, we will endeavour to provide you with suitable choices as to how to access it (e.g. by mail or email).
If we are satisfied that personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading (“faulty information”) or you request us to correct the information, we will, within a reasonable period after we identify the faulty information or the request is made, take such steps as are reasonable to correct the information.
SECURITY OF YOUR PERSONAL INFORMATION
Your personal information may be stored in hardcopy or electronically. We will take reasonable steps to protect personal information we hold from misuse, interference and loss as well as unauthorised access, modification or disclosure. We use current techniques and processes to protect personal information. Where we no longer need personal information for any purpose for which the information may be used or disclosed we will take reasonable steps to destroy the information or ensure the information is de-identified in accordance with the requirements of the Privacy Act.
WEBSITE
When you browse through the pages of the website, read or download information, we may collect or note details about your visit such as:
- your server / Internet Protocol address
- your operating system, top level domain name and the type of web browser you use
- the date, time and duration of your visit to the website
- whether you have visited the website previously and what content you viewed.
The information we may collect relates to your server or PC rather than you yourself (except where personal information is provided to CXC Global). The information we may collect may be used within CXC Global to help us improve the website by tailoring it to better suit your needs, and to provide quicker and more effective access to the various components of the website. We may disclose this information to other persons for these purposes or for related purposes, including to information technology companies who assist us in constructing, designing and maintaining the website.
We may also collect your personal details if you request information about CXC Global that we may supply online, or if you request, email or telephone us with a comment or query. We may use your details:
- to send you the information you have ordered
- to answer your comment or query
- to monitor our responses to you
- for our internal sales and marketing analysis.
If necessary, we may also contact you to follow up on your request, or to provide you with further information which may be of interest to you.
CONTACT US ABOUT YOUR PRIVACY
You can contact us via the contact details below if you:
- wish to access, update or correct your personal information
- wish to request not to receive direct marketing communications
- require further information about how we handle personal information
- have a complaint or concern in relation to privacy.
We will take any issue or concern relating to your privacy matter or complaint seriously and will take all reasonable steps to address your matter or complaint. If you are not satisfied with our handling of your privacy related matter or complaint, you may make a complaint to the Australian Information Commissioner.
Contact details:
The Privacy Officer
CXC Global
PO Box 7217
Warringah Mall Shopping Centre
Brookvale NSW 2100
Email: privacy@CXCGlobal.com
This privacy policy was last updated in March 2014.
Europe, Middle East, Africa Privacy Policy
CXC Global respects your privacy and we are committed to protecting your right to privacy.
This statement sets out how we collect, use, process and disclose personal data that we collect from you, or that you provide to us on our website and mobile website, www.CXCGlobal.com (Website). This statement includes the relevant requirement of the General Data Protection Regulation. It applies to both your visit to our website (regardless of where you visit it from) and when you use our services. This statement should be read in conjunction with our cookie policy.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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. This privacy notice supplements the other notices and is not intended to override them.
CONTROLLER
CXC Global is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice). When we refer to CXC Global we mean:
CXC Corporate Manage Services (CMS)
Company Reg No.: 558888
Registered address: The Black Church, St Mary’s Place, Dublin, 7, Ireland
CXC GLOBAL
This privacy statement is in respect of personal data collected by CXC Global.
COLLECTION OF PERSONAL DATA
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
As part of our services, we may need to collect use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments from you.
- Technical Data includes for example internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, the URL linking you to our website and other technology on the devices you use to access our website.
- Communications Data includes your preferences in receiving communications from us.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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 it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We may collect data that falls into Special Categories of Personal Data about you (this includes 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) but will not do this without a legitimate condition for processing.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, signing up to our newsletter or by corresponding with us by post, phone, email or otherwise.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your browsing actions. We collect this personal data by using cookies. We also collect personal data automatically when you use our Website, as explained in our cookie policy.
If you fail to provide personal data we may not be able to perform services we offer to you.
USES MADE OF 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 it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example to provide you with information about services you have requested;
- Where we need to comply with a legal or regulatory obligation;
- Where processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent; and/or
- Where processing is carried out in the course of our legitimate activities with appropriate safeguards by us and only when that processing relates solely to our users or to former users or to persons who have regular contact with us in connection with our purposes and that the personal data is not disclosed outside CXC Global without the consent of the data subjects.
Generally we do not rely on consent as a legal basis for processing your personal data.
For the purpose of our providing services to you, we shall use personal data and may share it with CXC Global staff. The legal basis for the processing of such data is for the performance of a contract with you or to comply with a legal obligation or where it is necessary for our legitimate interest in providing legal services to you. We may disclose personal data to our services company or holding company and to third party service providers (such as our partners, agents, credit card providers, Banks, IT service providers) as well as with third parties (such as third party experts and regulators) where required by law, where necessary to administer our working relationship with you or where we have a legitimate interest in doing so. We may also use personal information where it is needed in the public interest or for official purposes.
We have set out below, in a table format, a description of some of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. (Please see ‘Contact Us’ below)
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a service user | (a) Identity (b) Contact | Necessary for our legitimate interests |
To process payments: (a) Manage payments, fees and charges (b) Collect and recover money owed to us. | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | Necessary for our legitimate interests |
To manage our relationship with you which will include: (a) Notify you about information relevant to your purchase with us; (b) Notifying you about changes to our terms or privacy policy | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our organisation and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) 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 reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To make suggestions and recommendations to you about services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests (to develop our services and grow our business) |
We may use personal data to send you ezines, newsletters, invitations to seminars and similar marketing but we shall seek your consent to receiving such marketing materials from us. If at any time you decide that you do not wish to receive marketing emails from us, you can opt out by emailing privacy@CXCGlobal.com
COOKIES
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. For more information about the cookies we use, please see our cookie policy.
DISCLOSURE OF YOUR PERSONAL DATA
We may disclose your personal data to third parties who provide a service to us (eg our internet service provider) and are bound by confidentiality provisions or in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or where necessary for our legitimate business interests to protect the rights, property, or safety of CXC Global, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Communication of information via the Internet and by email is not completely secure and involves the information passing through third parties. In addition, communication of information via the Internet and by email may involve the transfer of personal data to third parties outside of the European Economic Area (EEA). To the limited extent that it is necessary to transfer your personal data outside of the EEA, 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. Please contact us if you wish to obtain information concerning such safeguards (see ‘Contact Us’ below).
DATA RETENTION
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.
If we no longer need the personal data for the purpose it was collected, we will take reasonable steps to ensure that such data is erased or anonymised, unless we are required or authorised by the applicable privacy law to retain the personal data.
To determine the appropriate retention period for 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 data retention policy which you can request from us by contacting us. (See ‘Contact Us’ below).
In some circumstances you can ask us to delete your data: see request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR RIGHTS
In 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 – provided that we are not required to retain the data for the performance of your employment contract or to comply with our legal obligations. Any deletion of personal data may impact on our ability to provide a reference for you.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and you want to object to processing on this ground.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, 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 our Data Protection Officer (“DPO”) ( TBD ). All requests should be sent to our DPO in writing by email or post (please see ‘Contact Us’ below). We will respond to your request as soon as possible and in any event within one month of receipt. We may request additional information from you to verify your identity and to enable us to respond to your request. 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.
In circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email privacy@CXCGlobal.com.
Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
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 on 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.
However, no data transmission over the internet can be 100% secure, and so we cannot guarantee the security of any information you send to us over the internet. Any transmission of such information is at your own risk.
THIRD PARTY PROCESSORS
Our information technology systems are operated by CXC Global but some data processing is carried out on our behalf by a third party. Where processing of personal data is carried out by a third party data processor on our behalf we endeavour to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal data. Our data processor is BS 10012:2017 certified as the best practice framework when collecting, storing, processing, retaining or disposing of personal records associated with individuals.
LINKS TO THIRD PARTY WEBSITES
Our Website may contain links to and from other websites, plug-ins and/or 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. When you leave our website, we encourage you to read the privacy notice of every website you visit. Please note that we do not accept any responsibility or liability if you follow a link to any of those websites.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by following the opt out links in any marketing message sent to you or by emailing privacy@CXCGlobal.com (For more information please see ‘Contact Us’ below). Where you opt out of receiving these messages, this will not apply to personal data provided to us as a result of a service we have provided.
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.
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
AMENDMENTS TO THIS STATEMENT
We reserve the right to change this privacy statement at any time. Any changes will be posted here and we will update the “Last Updated” date at the bottom of this statement. When you use our Website after any such change, you will be deemed to have appraised to the current version of the privacy statement and accordingly you should check the privacy statement from time to time.
Last updated: July 2024
It is important that all personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
CONTACT US
If you have any requests to exercise your legal rights or questions or concerns which specifically relate to how your personal data is processed by us via our Website please contact us using the details set out below.
Contact: The Privacy Officer
Email address: privacy@CXCGlobal.com
Postal address: CXC Corporate Manage Services (CMS), The Black Church, St Mary’s Place, Dublin, 7, Ireland
You have the right to make a complaint at any time to the Data Protection Commission (DPC), Ireland’s independent national authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.
North America Privacy Policy
CXC Global respects your privacy and we are committed to protecting your right to privacy.
This statement sets out how we collect, use, process and disclose personal data that we collect from you, or that you provide to us on our website and mobile website, www.CXCGlobal.com (Website). This statement includes the relevant requirement of the General Data Protection Regulation. It applies to both your visit to our website (regardless of where you visit it from) and when you use our services. This statement should be read in conjunction with our cookie policy.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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. This privacy notice supplements the other notices and is not intended to override them.
CONTROLLER
CXC Global is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
When we refer to CXC Global we mean:
CXC Global USA Inc
Register address: Suite 218, 4th Floor 10260 SW Greenburg Rd, Portland, OR United States
CXC GLOBAL
This privacy statement is in respect of personal data collected by CXC Global.
COLLECTION OF PERSONAL DATA
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
As part of our services, we may need to collect use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments from you.
- Technical Data includes for example internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, the URL linking you to our website and other technology on the devices you use to access our website.
- Communications Data includes your preferences in receiving communications from us.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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 it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We may collect data that falls into Special Categories of Personal Data about you (this includes 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) but will not do this without a legitimate condition for processing.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, signing up to our newsletter or by corresponding with us by post, phone, email or otherwise.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your browsing actions. We collect this personal data by using cookies. We also collect personal data automatically when you use our Website, as explained in our cookie policy.
If you fail to provide personal data we may not be able to perform services we offer to you.
USES MADE OF 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 it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example to provide you with information about services you have requested;
- Where we need to comply with a legal or regulatory obligation;
- Where processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent; and/or
- Where processing is carried out in the course of our legitimate activities with appropriate safeguards by us and only when that processing relates solely to our users or to former users or to persons who have regular contact with us in connection with our purposes and that the personal data is not disclosed outside CXC Global without the consent of the data subjects.
Generally we do not rely on consent as a legal basis for processing your personal data.
For the purpose of our providing services to you, we shall use personal data and may share it with CXC Global staff. The legal basis for the processing of such data is for the performance of a contract with you or to comply with a legal obligation or where it is necessary for our legitimate interest in providing legal services to you. We may disclose personal data to our services company or holding company and to third party service providers (such as our partners, agents, credit card providers, Banks, IT service providers) as well as with third parties (such as third party experts and regulators) where required by law, where necessary to administer our working relationship with you or where we have a legitimate interest in doing so. We may also use personal information where it is needed in the public interest or for official purposes.
We have set out below, in a table format, a description of some of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. (Please see ‘Contact Us’ below)
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a service user | (a) Identity (b) Contact | Necessary for our legitimate interests |
To process payments: (a) Manage payments, fees and charges (b) Collect and recover money owed to us. | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | Necessary for our legitimate interests |
To manage our relationship with you which will include: (a) Notify you about information relevant to your purchase with us; (b) Notifying you about changes to our terms or privacy policy | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our organisation and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) 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 reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To make suggestions and recommendations to you about services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests (to develop our services and grow our business) |
We may use personal data to send you ezines, newsletters, invitations to seminars and similar marketing but we shall seek your consent to receiving such marketing materials from us. If at any time you decide that you do not wish to receive marketing emails from us, you can opt out by emailing privacy@cxcglobal.com
COOKIES
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. For more information about the cookies we use, please see our cookie policy.
DISCLOSURE OF YOUR PERSONAL DATA
We may disclose your personal data to third parties who provide a service to us (eg our internet service provider) and are bound by confidentiality provisions or in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or where necessary for our legitimate business interests to protect the rights, property, or safety of CXC Global, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Communication of information via the Internet and by email is not completely secure and involves the information passing through third parties. In addition, communication of information via the Internet and by email may involve the transfer of personal data to third parties outside of the European Economic Area (EEA). To the limited extent that it is necessary to transfer your personal data outside of the EEA, 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. Please contact us if you wish to obtain information concerning such safeguards (see ‘Contact Us’ below).
DATA RETENTION
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.
If we no longer need the personal data for the purpose it was collected, we will take reasonable steps to ensure that such data is erased or anonymised, unless we are required or authorised by the applicable privacy law to retain the personal data.
To determine the appropriate retention period for 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 data retention policy which you can request from us by contacting us. (See ‘Contact Us’ below).
In some circumstances you can ask us to delete your data: see request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR RIGHTS
In 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 – provided that we are not required to retain the data for the performance of your employment contract or to comply with our legal obligations. Any deletion of personal data may impact on our ability to provide a reference for you.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and you want to object to processing on this ground.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, 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 our Data Protection Officer (“DPO”) ( TBD ). All requests should be sent to our DPO in writing by email or post (please see ‘Contact Us’ below). We will respond to your request as soon as possible and in any event within one month of receipt. We may request additional information from you to verify your identity and to enable us to respond to your request. 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.
In circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email privacy@CXCGlobal.com.
Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
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 on 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.
However, no data transmission over the internet can be 100% secure, and so we cannot guarantee the security of any information you send to us over the internet. Any transmission of such information is at your own risk.
THIRD PARTY PROCESSORS
Our information technology systems are operated by CXC Global but some data processing is carried out on our behalf by a third party. Where processing of personal data is carried out by a third party data processor on our behalf we endeavour to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal data. Our data processor is BS 10012:2017 certified as the best practice framework when collecting, storing, processing, retaining or disposing of personal records associated with individuals.
LINKS TO THIRD PARTY WEBSITES
Our Website may contain links to and from other websites, plug-ins and/or 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. When you leave our website, we encourage you to read the privacy notice of every website you visit. Please note that we do not accept any responsibility or liability if you follow a link to any of those websites.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by following the opt out links in any marketing message sent to you or by emailing privacy@CXCGlobal.com. (For more information please see ‘Contact Us’ below). Where you opt out of receiving these messages, this will not apply to personal data provided to us as a result of a service we have provided.
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.
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
AMENDMENTS TO THIS STATEMENT
We reserve the right to change this privacy statement at any time. Any changes will be posted here and we will update the “Last Updated” date at the bottom of this statement. When you use our Website after any such change, you will be deemed to have appraised to the current version of the privacy statement and accordingly you should check the privacy statement from time to time.
Last updated: June 2023
It is important that all personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
CONTACT US
If you have any requests to exercise your legal rights or questions or concerns which specifically relate to how your personal data is processed by us via our Website please contact us using the details set out below.
Contact: The Privacy Officer
Email address: privacy@CXCGlobal.com
Postal address: Postal address: 16000 Bothell Everett Hwy Mill Creek WA 98012
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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Latin America Privacy Policy
CXC Global respects your privacy and we are committed to protecting your right to privacy.
This statement sets out how we collect, use, process and disclose personal data that we collect from you, or that you provide to us on our website and mobile website, www.CXCGlobal.com (Website). This statement includes the relevant requirement of the General Data Protection Regulation. It applies to both your visit to our website (regardless of where you visit it from) and when you use our services. This statement should be read in conjunction with our cookie policy.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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. This privacy notice supplements the other notices and is not intended to override them.
CONTROLLER
CXC Global is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice). When we refer to CXC Global we mean:
CXC Global EMEA UK Limited
Company Number: 10401238
Registered address: Bradleys, 81A Bellegrove Road, Welling, Kent, England, DA16 3PG
CXC GLOBAL
This privacy statement is in respect of personal data collected by CXC Global.
COLLECTION OF PERSONAL DATA
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
As part of our services, we may need to collect use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments from you.
- Technical Data includes for example internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, the URL linking you to our website and other technology on the devices you use to access our website.
- Communications Data includes your preferences in receiving communications from us.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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 it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We may collect data that falls into Special Categories of Personal Data about you (this includes 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) but will not do this without a legitimate condition for processing.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, signing up to our newsletter or by corresponding with us by post, phone, email or otherwise.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your browsing actions. We collect this personal data by using cookies. We also collect personal data automatically when you use our Website, as explained in our cookie policy.
If you fail to provide personal data we may not be able to perform services we offer to you.
USES MADE OF 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 it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example to provide you with information about services you have requested;
- Where we need to comply with a legal or regulatory obligation;
- Where processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent; and/or
- Where processing is carried out in the course of our legitimate activities with appropriate safeguards by us and only when that processing relates solely to our users or to former users or to persons who have regular contact with us in connection with our purposes and that the personal data is not disclosed outside CXC Global without the consent of the data subjects.
Generally we do not rely on consent as a legal basis for processing your personal data.
For the purpose of our providing services to you, we shall use personal data and may share it with CXC Global staff. The legal basis for the processing of such data is for the performance of a contract with you or to comply with a legal obligation or where it is necessary for our legitimate interest in providing legal services to you. We may disclose personal data to our services company or holding company and to third party service providers (such as our partners, agents, credit card providers, Banks, IT service providers) as well as with third parties (such as third party experts and regulators) where required by law, where necessary to administer our working relationship with you or where we have a legitimate interest in doing so. We may also use personal information where it is needed in the public interest or for official purposes.
We have set out below, in a table format, a description of some of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. (Please see ‘Contact Us’ below)
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a service user | (a) Identity (b) Contact | Necessary for our legitimate interests |
To process payments: (a) Manage payments, fees and charges (b) Collect and recover money owed to us. | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | Necessary for our legitimate interests |
To manage our relationship with you which will include: (a) Notify you about information relevant to your purchase with us; (b) Notifying you about changes to our terms or privacy policy | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our organisation and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) 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 reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To make suggestions and recommendations to you about services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests (to develop our services and grow our business) |
We may use personal data to send you ezines, newsletters, invitations to seminars and similar marketing but we shall seek your consent to receiving such marketing materials from us. If at any time you decide that you do not wish to receive marketing emails from us, you can opt out by emailing privacy@CXCGlobal.com.
COOKIES
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. For more information about the cookies we use, please see our cookie policy.
DISCLOSURE OF YOUR PERSONAL DATA
We may disclose your personal data to third parties who provide a service to us (eg our internet service provider) and are bound by confidentiality provisions or in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or where necessary for our legitimate business interests to protect the rights, property, or safety of CXC Global, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Communication of information via the Internet and by email is not completely secure and involves the information passing through third parties. In addition, communication of information via the Internet and by email may involve the transfer of personal data to third parties outside of the European Economic Area (EEA). To the limited extent that it is necessary to transfer your personal data outside of the EEA, 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. Please contact us if you wish to obtain information concerning such safeguards (see ‘Contact Us’ below).
DATA RETENTION
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.
If we no longer need the personal data for the purpose it was collected, we will take reasonable steps to ensure that such data is erased or anonymised, unless we are required or authorised by the applicable privacy law to retain the personal data.
To determine the appropriate retention period for 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 data retention policy which you can request from us by contacting us. (See ‘Contact Us’ below).
In some circumstances you can ask us to delete your data: see request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR RIGHTS
In 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 – provided that we are not required to retain the data for the performance of your employment contract or to comply with our legal obligations. Any deletion of personal data may impact on our ability to provide a reference for you.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and you want to object to processing on this ground.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, 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 our Data Protection Officer (“DPO”) ( TBD ). All requests should be sent to our DPO in writing by email or post (please see ‘Contact Us’ below). We will respond to your request as soon as possible and in any event within one month of receipt. We may request additional information from you to verify your identity and to enable us to respond to your request. 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.
In circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email privacy@CXCGlobal.com.
Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
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 on 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.
However, no data transmission over the internet can be 100% secure, and so we cannot guarantee the security of any information you send to us over the internet. Any transmission of such information is at your own risk.
THIRD PARTY PROCESSORS
Our information technology systems are operated by CXC Global but some data processing is carried out on our behalf by a third party. Where processing of personal data is carried out by a third party data processor on our behalf we endeavour to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal data. Our data processor is BS 10012:2017 certified as the best practice framework when collecting, storing, processing, retaining or disposing of personal records associated with individuals.
LINKS TO THIRD PARTY WEBSITES
Our Website may contain links to and from other websites, plug-ins and/or 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. When you leave our website, we encourage you to read the privacy notice of every website you visit. Please note that we do not accept any responsibility or liability if you follow a link to any of those websites.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by following the opt out links in any marketing message sent to you or by emailing privacy@CXCGlobal.com. (For more information please see ‘Contact Us’ below). Where you opt out of receiving these messages, this will not apply to personal data provided to us as a result of a service we have provided.
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.
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
AMENDMENTS TO THIS STATEMENT
We reserve the right to change this privacy statement at any time. Any changes will be posted here and we will update the “Last Updated” date at the bottom of this statement. When you use our Website after any such change, you will be deemed to have appraised to the current version of the privacy statement and accordingly you should check the privacy statement from time to time.
Last updated: June 2023
It is important that all personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
CONTACT US
If you have any requests to exercise your legal rights or questions or concerns which specifically relate to how your personal data is processed by us via our Website please contact us using the details set out below.
Contact: The Privacy Officer
Email address: privacy@CXCGlobal.com
Postal address: CXC Global EMEA UK, Bradleys, 81A Bellegrove Road, Welling, Kent, England, DA16 3PG
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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
