XSPOT

Last Updated: 20/06/2024

HOW XSPOT COLLECTS YOUR INFORMATION:

Sources of personal information and personal information we collect:

XSPOT collects personal information from several different sources, including:

Directly from a visitor to the Site|App, including jobseekers.

From service providers or other third parties; and

Automatically, from the visit or activity of a Site|App visitor on our Site|App.

How we collect personal information:

XSPOT collects personal information when you visit our Site|App and when you choose to provide personal information. For example, we collect information when you contact us through our Site|App, provide your e-mail address, telephone number or other similar contact information, such as the information you provide when you register for a webinar. Jobseekers who complete a job application on XSPOT or create a profile on this Site|App may also provide credentials and other information relevant to the job application.

HOW XSPOT USES PERSONAL INFORMATION

Why we use your personal information:

XSPOT relies on legal grounds, such as Performance of Contract or Legitimate Interest. In addition, we may process personal information for the following purposes:

• To fulfill the purpose(s) for which the information was collected or provided, including to communicate with you and respond to your questions and requests.
• To improve our web Site|App, products and services through testing, research, analysis and product development.
• To market, advertise and promote our products and services, for example, to make suggestions and recommendations about products or services that may be of interest to you.
• To provide support and information about our products and services through our support line, available 24 hours a day, 7 days a week on our Site|Apps.
• To provide training related to the products and services, such as making available training materials or events (in person or online) for which we may use your personal information to provide you with notices and information about such training and events.
• For security, auditing, internal investigation and fraud prevention purposes, such as to prevent unauthorized access or disclosure, maintain data accuracy, protect the confidentiality, integrity and availability of your personal information; allow only appropriate use of your personal information; identify any fraudulent, harmful, unauthorized, unethical or illegal activity.
• To manage litigation, for example in connection with the establishment, exercise or enforcement of a legal claim.

WHEN XSPOT DISCLOSES YOUR PERSONAL INFORMATION

Please note that XSPOT does not sell personal information to third parties. The term "sell", as defined by applicable laws, means the disclosure of personal information to third parties for monetary purposes or other valuable consideration.

Affiliates:

We may disclose your personal information to our affiliates in order to facilitate the delivery of a product or service or to complete a task you have requested.

Third parties (suppliers/service providers):

We may engage with third parties (vendors and/or service providers) to facilitate the delivery of a product or service (or perform certain functions, such as enhancing and/or delivering our product and service offerings); complete a task you have requested; provide training; perform marketing and advertising; operate, secure and optimize the Site|App; and coordinate and work with our partners.

We have contracts with these third parties to perform certain functions on our behalf and only at our direction. These third parties are bound by contracts which contain confidentiality and other data protection terms designed to ensure that the third parties use your personal information only to the extent necessary to provide these contracted services in accordance with our instructions (and for the purposes we disclose).

XSPOT may use the support for marketing purposes, such as managing email campaigns. In these circumstances, XSPOT is the data controller and a virtual assistant (chatbot) acts as a processor. Data Protection Agreements are in place to ensure that the privacy and use of your data complies with this Notice.

Additional disclosures

We may disclose your personal information as necessary to:

• Providing customer service or technical support in relation to training or webinars that you have signed up for or attended.
• For administration and business operation purposes and to keep a record of your relationship with us.
• To comply with the law or legal obligations, such as to law enforcement officials, government authorities or other third parties in response to a lawful request for information by a competent authority, if we believe disclosure is pursuant to, or is otherwise required by, any applicable law, regulation or legal process, including to meet national security or law enforcement requirements.
• To manage disputes and conduct internal audits and investigations, such as to protect and defend our rights and property, investigate fraudulent or illegal activities and conduct internal financial, security or other audits.
• To protect against misuse or unauthorized use of our Site|App, products and services.
• Protecting the personal safety or property of our users or the public (among other things, this means that if you provide false information or try to use someone else's identity, information about you may be disclosed as part of any investigation into your actions).
• In connection with, or during the negotiation of, any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or for another company, including the transfer of contact information and customer, partner and end user data.
• In an aggregated and unidentified or anonymous form; and
• When we have your consent to share the information.

Except as stated in this Site|App Notice, we will endeavor not to disclose your personal information to unknown or unaffiliated third parties, and we will not cross-reference your personal information with that of any other customer or entity.

RETENTION OF PERSONAL INFORMATION

XSPOT will only retain personal information for as long as necessary to fulfill the purpose(s) for which the information was collected or as required or permitted by applicable laws (including dispute resolution) and in accordance with our client agreements.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process your personal information and whether we can achieve those purposes by other means in addition to applicable legal requirements.

When we no longer need your personal information, we will delete or de-identify it or, if this is not possible, we will store it securely in accordance with this Site|App Notice and stop using the personal information until deletion is possible. If we de-identify your personal information (so that it is no longer associated with you), we may retain this information for longer periods.

RIGHTS OF THE DATA SUBJECT

Subject to and depending on applicable law, you may be entitled to exercise some or all of the following rights in relation to our collection, use and sharing of your personal information:

• Access the personal information we hold about you.
• Update or correct any inaccurate or incomplete personal information about you.
• Request the deletion of your personal information.
• Object to or restrict the processing of your personal information.
• Receive the personal information you previously provided to XSPOT in a machine-readable format, allowing you to transfer this personal information to another company at your discretion.
• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you in a similar way; and
• File a complaint directly with your government representative (such as the Supervisory Authority) about how we process your personal information.
• Dispute resolution.

Changes to the Privacy Policy

We may update this privacy policy from time to time. The update version will be published in our website. We encourage you to review this privacy policy regularly.