This privacy notice describes how and why we process your personal information. Your privacy is very important to us and we are committed to using your personal information lawfully and protecting your privacy.
- What information RoxAI may collect about you and on what basis;
- How RoxAI will use information we collect about you;
- When RoxAI may use your details to contact you;
- Whether RoxAI will disclose your details to anyone else;
- Your choices regarding the personal information you provide to us;
02 Who are we?
RoxAI is a UK based Software company with offices in the UK, Dubai & India. We do have clients and partners from all over the world and this policy is intended to comply with UK/EU requirements only. If you are outside of the EU and you have any concerns please do not hesitate to contact us for more information about how we can help you.
- When we refer to RoxAI we are referring to RoxAI Ltd.
03 What information will RoxAI collect about me?
When you participate in, access or sign up to any of RoxAI services, activities or online content, such as downloads, newsletters, competitions, live chats, message boards, telephone or text RoxAI, vote, donate money to a RoxAI charity appeal, register to attend for a RoxAI event or create an account using RoxAI online registration systems we may receive personal information about you.
This can consist of information such as your name, email address, postal address, telephone or mobile number, confirmation of adult age, or date of birth*, depending on the activity. [*future]
By submitting your details, you enable RoxAI (and where applicable its contractors) to provide you with the services, activities or online content you select.
Please note that sometimes we will require you to provide additional personal information, and sometimes sensitive personal information (e.g. if you’re sending in an application to be a contractor for a secure site we may need to know and collect data your political leanings and personal circumstances). When we do this, we will provide further information as to why we are collecting your information and how we will use it.
We will only collect, hold, use and/or process (together “process”) your personal information where we are legally allowed to do so. We will ensure that your personal information is:
- processed lawfully, fairly and transparently
- collected for specific, explicit and legitimate purposes
- adequate, relevant and limited to what is necessary for the purpose of the processing
- kept accurate and up to date
- only kept for so long as is necessary
- processed securely using reasonable and appropriate technical and organisational measures to ensure integrity and confidentiality
We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services:
where we process your personal information for contractual performance. This includes:
- Enabling us to take steps you request prior to us entering into a contract; and then;
- Once we have entered into a contract, to enable us to perform the contract and to provide you with the products and services. We will process your personal information in accordance with the contract.
We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include:
- Delivering services to our clients – To deliver the professional services our clients have engaged us to provide.
- Direct marketing – To deliver timely market insights and specialty knowledge we believe is welcomed by our business clients, subscribers and individuals who have interacted with us. Where we process your personal information for our interests we will do so only where we have carefully considered both our and your interests. We will not process your personal information if our interests are overridden by your interests or fundamental rights and freedoms.
where we rely solely on your consent to process your personal information
There may be circumstances where we need to, or are required to obtain and/or rely upon your consent to process your personal information. If this is the case we will give you:
- the reason for needing your consent, including details as to how we will process your information
- the choice as to whether to provide consent
- information to enable you to withdraw your consent
04 How will RoxAI use the information it collects about me?
RoxAI will use your personal information for a number of purposes including the following:
- to provide our services, activities or online content and to deal with your requests and enquiries;
- for service administration purposes, which means that RoxAI may contact you for reasons related to the service, activity or online content you have signed up for, as set out in section 5 below (e.g. to provide you with password reminders or to notify you that a particular service, activity or online content has been suspended for maintenance);
- to contact you about a submission you have made, including any content you provide.
- to provide you with information about our services, activities or online content;
- to personalise the way RoxAI content is presented to you (e.g. if the first thing you look at every day on RoxAI website is the weather for Luton, we may present this information or a link to it on your homepage);
- to use IP addresses to identify the location of users, to block disruptive use, to establish the number of visits from different countries and to determine whether you are accessing the services from the UK or not. If not, you may be re-directed to a more appropriate eg international versions of our web pages (see section 12 for details);
- to analyse and improve the services offered on RoxAI websites;
- to provide you with the most user-friendly navigation experience. RoxAI may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes; and
- when you access RoxAI website from outside the UK, you may see international based web pages which may feature advertising. A certain amount of this advertising is tailored to the individual user and location.
- Where RoxAI proposes using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed above.
05 When will RoxAI contact me?
RoxAI may contact you:
- in relation to any service, activity or on-line content you have signed up for in order to ensure that RoxAI can deliver the services to you;
- in relation to any correspondence we receive from you or any comment or complaint you make about RoxAI products or services;
- in relation to any contribution you have submitted to RoxAI, e.g. on RoxAI message boards or via text or voice mail message;
- to invite you to participate in surveys about RoxAI services (participation is always voluntary); and
- for marketing purposes, either where we have legitimate reason to do so, or you have specifically agreed to this (see section 6 below).
- Relevant webpages will give you detailed information about how RoxAI will contact you in relation to specific services, activities or on-line content.
06 Will I be contacted for marketing purposes?
RoxAI will only use your personal information provided by you for marketing purposes, or to promote new services, activities or on-line content where you have agreed to this.
07 Will RoxAI share my personal information with anyone else?
- We will keep your information confidential except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies) or as described in section 8 below. Generally, we will only use your information within RoxAI. However, sometimes RoxAI uses third parties to process your information on our behalf. RoxAI requires these third parties to comply strictly with its instructions and RoxAI requires that they do not use your personal information for their own business purposes, unless you have explicitly consented to the use of your personal information in this way. We will never sell your information to a third party.
- We will only share your information with a third party or transfer your data outside of the UK / EU if we need to. Where we do this we will comply with all of our legal obligations and we ensure that there are adequate protections in place to protect your information.
If we need your consent we will:
- explain why we need to share your personal information
- explain the purpose for which we will be sharing it
- provide you with details of the third party
- obtain your explicit consent for such.
- You will be able to easily withdraw your consent in the same way in which you gave it.
- Where we rely on a different lawful basis, such as ‘legitimate interests’ or ‘contractual’, we will do so only to the extent permitted by such lawful basis.
08 Offensive or inappropriate content on RoxAI websites:
If you post or send offensive, inappropriate or objectionable content anywhere on or to RoxAI websites or otherwise engage in any disruptive behaviour on any RoxAI service, RoxAI may use your personal information to stop such behaviour.
Where RoxAI reasonably believes that you are or may be in breach of any applicable laws (e.g. because content you have posted may be defamatory), RoxAI may use your personal information to inform relevant third parties such as your employer, school email/internet provider or law enforcement agencies about the content and your behaviour.
09 What if I am a user aged 16 or under?
RoxAI policy is not to engage nor keep information on persons under 16 years of age. If you are aged 16 or under, please get your parent/guardian to provide any personal information to RoxAI on your behalf stating clearly the purpose for sharing such information. Only where it is necessary to comply with the law will such information be recorded and kept.
10 How long will RoxAI keep my personal information?
We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with RoxAI or RoxAI corporate retention schedule (a database that defines which documents should be kept and for how long). If your circumstances change a flag goes on the database and, while RoxAI cannot use the personal information, it stays on the system for a period of one year for administration purposes before being deleted automatically.
Where you contribute material to RoxAI we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted.
RoxAI, as brokers of contemporary thought, also has an obligation to record snapshots of history which may include some User Generated Content i.e. content provided by the public. Therefore, some content submitted to, or shared with, RoxAI may be retained for prolonged periods of time or potentially indefinitely in RoxAI Archive, which is true of News contributions which are published. There may also be rare instances where we will share your contribution with third parties in the interests of maintaining archives. Where possible, we will endeavour to inform you upfront or let you know at a later date where we are likely to keep content indefinitely.
11 Can I find out what personal information RoxAI holds about me?
12 What if I am accessing RoxAI websites outside the UK?
13 Cookies Policy – Information RoxAI collects from you
What is a cookie?
A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet or mobile phone (referred to here as a device) browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track on-line traffic flows.
On RoxAI websites, cookies record information about your on-line preferences and allow us to tailor our websites to your interests.
Information supplied by cookies can help us to analyse the profile of our visitors and help us to provide you with a better user experience. RoxAI uses this type of information to help improve the services it provides to its users. All third parties are strictly required not to use any information for their own business or other purposes (see section 6 above).
- Third Party Cookies in embedded content on RoxAI pages
Please note that during your visits to RoxAI websites you may notice some cookies that are not related to RoxAI or RoxAI’s contractors. When you visit a page with content embedded from, for example, YouTube or Flickr, you may be presented with cookies from these websites. RoxAI does not control the dissemination of these cookies. You should check the third party websites for more information about these. Find out more about third party cookies in embedded content.
- RoxAI cookies and how to reject cookies?
15 How do we secure your personal data?
We place a great deal of importance on the security of all personal information. We have in place appropriate technical and security measures which are reviewed routinely. Our approach to information security is validated by our internal security audit performed by the Head of Technology.
16 Your rights; including your right to object and right to withdraw consent
We respect and place significant importance on your rights. The recently EU adopted General Data Protection Regulations outlines your rights, and provides further information in relation to those rights and details what we must and will do, when you wish to exercise your rights. In summary, your rights include the right to:
- Basic information (such as our identity, or that of the controller if not us, the reason and basis on which we process your personal data, together with as much information to ensure fairness and transparency) and to be informed
- Object: to object to processing of personal data where such is done by us in certain circumstances, for example for our legitimate interests or direct marketing
- Withdraw consent: to withdraw your previously given consent
- Access: to be aware of and verify the lawfulness of the processing
- Rectification: to correct personal data if it is inaccurate or incomplete
- Erasure: to request the removal or deletion of personal data
- Restrict processing: to restrict the processing of personal data
- Data portability: to obtain and reuse personal data
- Be aware of any automated decision making or profiling, and to request such is restricted
If you wish to object or to withdraw consent, you may contact us though one of the methods detailed below in the ‘Contact us’ section. In addition, where we have sent you a marketing email, we will have provided an ‘unsubscribe’ or ‘set your preferences’ or ‘opt-out’ link which you can use to stop any future marketing communications.
14 Hanover Street
Attn: The Data Protection Officer
Or email firstname.lastname@example.org
For full contact details see: