We have issued this privacy policy to describe how we handle the personal data that we process.

We respect the privacy rights of individuals and are committed to handling personal data responsibly and in accordance with applicable law.

This policy sets out the personal data that we collect and process about you, the purposes of the processing and the rights that you have in connection with it.

When making an inquiry, we may record and process personal data about you and other individuals whose personal data has been provided to us.

Personal Data

The types of personal information we may process include:

• Identification data – such as your name and IP address.
• Contact details – such as your postal address, telephone number and email address.
• Other data – Any other information you may choose to share when communicating with us.

Special Category Data

We do not collect special category data.

General Enquiries

When making an enquiry about our games or services, we may collect and use your personal data for the purpose of contacting you.

Careers Enquiries

When making an enquiry about a job with Exient, we may collect and use your personal data for the purpose of contacting you. 

If you are put forward as a suitable candidate then the information provided will be used to support your application. Should you become an employee of Exient, then this information will be kept alongside your employee record.

Under Article 6 GDPR and depending on the nature of the enquiry, Exient may process personal data as per:

• The data subject has given consent to the processing of his or her personal data for one or more specific purposes;
• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which the controller is subject.

We take care to allow access to personal data only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it.

Whenever we permit a third party to access personal and special category data, we will implement appropriate measures to ensure such data is used in a manner consistent with this policy and that the security and confidentiality of the personal data is maintained.

In addition, we make certain personal data available to third parties who provide services to us. We do so on a “need to know basis” and in accordance with applicable data protection and data privacy laws.

For example, when applying for a job, we may share personal data between Exient Ltd (UK) and Exient Trade Company Ltd (Malta).

We may also disclose personal data to third parties on other lawful grounds, including:

• To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process
• In response to lawful requests by public authorities (including for national security or law enforcement purposes)
• As necessary to establish, exercise or defend against potential, threatened or actual litigation
• Where necessary to protect the vital interests of our employees or another person
• In connection with the sale, assignment or other transfer of all or part of our business; or
• With your freely given and explicit consent.

We use third party processors / service providers to process your data. These include cloud service providers providing services such as email, application tracking, staff administration, hosted databases, API interfaces and accounts. 

We may need to transfer personal and special category data to countries outside of the United Kingdom. If we export your personal data to a different country, we will take steps to ensure that such data exports comply with applicable laws. For example, if we transfer personal data outside the European Economic Area (EEA), such as to the United States, we will implement an appropriate data export solution such as entering into contracts with the data importer that contain EU or other acceptable standard model clauses or taking other measures to provide an adequate level of data protection.

Personal data is stored in accordance with applicable laws and kept for as long as needed to carry out the purposes described in this notice or as otherwise required by law.

Enquiries

Enquiries are retained for a period of 1 year following initial contact unless

1. services are provided;
2. a position of employment is offered;
3. consent is given to retain personal data for an extended period in the event future employment opportunities may be suitable for the enquirer.

We have put in place appropriate security measures to prevent your personal and special category 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.

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. We may need to request confirmation of identity to ensure you have a right to access this data.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• The right to object to automated processing which makes decisions regarding the rights of the individual without human involvement.

If you wish to exercise any of the rights set out above, please contact us at ukgdpr@exient.com.

We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This notice was drafted with clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed.

If you want to make a complaint about the way we have processed your personal information, you can contact the Data Protection Officer via ukgdpr@exient.com.

You can also make a complaint to the Information Commissioner, who is an independent regulator by:

Telephone: +44 303 123 1113

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Exient is registered with the Information Commissioners Office under registration number: ZA494378.

This notice may be updated periodically to reflect any necessary changes in our privacy practices. In such cases, if we have relevant contact details then we will inform you of such changes.

We encourage you to check this policy periodically to be aware of the most recent version.

Please address any questions or requests relating to this notice to the Data Protection Officer.

Data Protection Officer
Althorpe Enterprise Hub
Althorpe Street
Leamington Spa
CV31 2GB
United Kingdom

Email: ukgdpr@exient.com