PRIVACY POLICY

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint. We collect, use and are responsible for certain personal information about you. When we do so we are subject to the Data Protection Act 2018, the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws. Where you reside in a county outside the UK/EEA, we will comply with local laws relating to your data.

KEY TERMS

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	iXensor Co., Ltd, 6F., No.9, Aly. 2, Ln. 35, Jihu Rd., Neihu Dist., Taipei 11492, Taiwan
Our data protection officer	The person appointed by us who is responsible for ensuring we comply with privacy and data laws who may be contacted by writing to FAO: Privacy Compliance Officer at dpo@ixensor.com. or iXensor Co., Ltd, 6F., No.9, Aly. 2, Ln. 35, Jihu Rd., Neihu Dist., Taipei 11492, Taiwan
Personal information	Any information relating to an identified or identifiable individual
Special category personal information	Personal information revealing, biometric data and data concerning health.

PERSONAL INFORMATION WE COLLECT ABOUT YOU

We may collect and use the following information below about you, but it is likely we will only collect a small proportion of it which will be dictated by the service you obtain from us:

• your full name and contact information, including email address and telephone number and company details.
• information to enable us to check and verify your identity, e.g., your date of birth.
• information to enable us to check and verify your identity, e.g., your date of birth.
• your gender information and biometric data which may include images of you.
• location data, such as your address, nationality, region and which countries you visit.
• your billing information, transaction and payment card information if we process payments or receive sums from you.
• information relating to the device you use to interact with our services.
• information regarding your health status, and health data which may include details relating to your heart rate, blood oxygen saturation, body temperature, whether you have (i) breathing difficulties (ii) a cough; (iii) weakness in your limbs; (iv) general malaise; (v) other symptoms you may have.
• we will also collect information relating to medical tests you undertake where you choose store the data within the application such as, the type of test you undertake, the time, date and location of the test, the test result.
• details relating to your employment such as who your employer is, its location, the users it appoints to review the data you share with your employer.
• information relating to which service providers you use, such as companies which provide travel services, leisure services or other services where you acquire such services in person.
• which companies you share your test results with.
• information in relation to the device you are using such as hardware/software specification, IP address, time and date you use our applications, how and what applications you use.

This personal information is required to provide products services to you, your employer or any third party you may choose to share the data with. If you do not provide personal information we ask for, it may delay or prevent us from providing our products and services to you.

HOW YOUR PERSONAL INFORMATION IS COLLECTED

We collect most of this personal information directly from you, or the third party undertaking a test on your behalf, and which you input through our web-based applications or the application you download on to your devices. However, we may also collect information:

• from publicly accessible sources.
• from a third party with your consent, e.g., your employer, bank, a service provider that you use.
• via our IT systems, for instance our applications, websites and other technical systems analyse how our customers/users interact with these programs so we can better understand what works well and how it is used.

HOW AND WHY WE USE YOUR PERSONAL INFORMATION

Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:

• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products and services to you	For the performance of our contract with you or to take steps at your request before entering into a contract or with you consent
To provide products and services to third parties	For the performance of our contract with you, with your consent and the service providers you interact with
To store health data on your behalf at your request	With your consent, our legitimate interests and to perform our contractual obligations
To prevent and detect fraud against you or your employer	For our legitimate interests or those of a third party, i.e., to minimise fraud that could be damaging for us and for you
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g., in relation to customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers
External audits and quality checks	For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

PROMOTIONAL COMMUNICATIONS

We may use your personal information to send you updates (by email, text message, telephone, post or through our application) about our products and/or services. We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. We will always treat your personal information with the utmost respect. You have the right to opt out of receiving promotional communications at any time by contacting us at dpo@ixensor.com. We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We routinely share personal information with:

• companies who you choose to share your data with
• third parties we use to help deliver our products and/or services to you, e.g., testing laboratories, payment service providers, delivery companies;
• other third parties we use to help us run our business, e.g., marketing agencies or website hosts;
• third parties approved by you, e.g., social media sites you choose to link your account to or third-party payment providers;

We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

WHERE YOUR PERSONAL INFORMATION IS HELD

Information may be held at our offices and those of our group companies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT

We will keep your personal information while you have an account with us, or we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different ¬ periods apply for different types of personal information. Further details on this are set out details of records management policy and/or schedule that gives these details. When it is no longer necessary to retain your personal information, we will delete or anonymise it.

TRANSFERRING YOUR PERSONAL INFORMATION OUT OF THE COUNTRY YOU LIVE IN

To deliver services to you, it is sometimes necessary for us to share your personal information outside the country you live in eg:

• with our offices or other companies within our group;
• with your and our service providers located outside the country or, if appropriate, EEA;
• where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules in European and UK data protection law. This means we can only transfer your personal information to a country or international organisation where:

• the country the data is transferred to has similar laws relating to data;
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
• a specific exception applies under data protection law

These are explained below.

TRANSFERS WITH APPROPRIATE SAFEGUARDS

We may transfer your data to a third country or international organisation on this ground where we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

TRANSFERS UNDER AN EXCEPTION

In the absence of appropriate safeguards, we may transfer personal information to a third country or international organisation where an exception applies under relevant data protection law, eg:

• you have explicitly consented to the proposed transfer after having been informed of the possible risks;
• the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
• the transfer is necessary for a contract in your interests, between us and another person; or
• the transfer is necessary to establish, exercise or defend legal claims

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal information on this ground.

FURTHER INFORMATION

If you would like further information about where data transferred outside your country, please contact us (see ‘How to contact us’ below).

YOUR RIGHTS

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal information (the right of access)
Rectification	The right to require us to correct any mistakes in your personal information
To be forgotten	The right to require us to delete your personal information—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data
Data portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us. If you would like to exercise any of those rights, please:

• email, call or write to us – see below: ‘How to contact us’; and
• let us have enough information to identify you (e.g., your full name, address and customer or matter reference number);
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.

KEEPING YOUR PERSONAL INFORMATION SECURE

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

IF YOU HAVE QUERIES OR CONCERNS

We hope that we can resolve any query or concern you may raise about our use of your information. If you have any queries, concerns or complaints about how we handle your data, please contact us at dpo@ixensor.com. In the unlikely event we are unable to resolve your queries, the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.

CHANGES TO THIS PRIVACY POLICY

This privacy notice was published in January 2021. We may change this privacy notice from time to time.

HOW TO CONTACT US

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you. Our contact details are shown below: FAO: Privacy Compliance Officer dpo@ixensor.com or iXensor Co., Ltd, 6F., No.9, Aly. 2, Ln. 35, Jihu Rd., Neihu Dist., Taipei 11492, Taiwan

DO YOU NEED EXTRA HELP?

If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).