Exro Technologies
Responsible Privacy

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.exro.com

Mo Farrokhi is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

If you need to email us about anything related to this privacy notice, you can email us at marketingops@exro.com or you can write to us at the address above

If any of your personal information changes, please email us at the above email address and let us know how it has changed. From time to time we may email you to check that the personal data we hold for you is accurate and up to date.

Where this document refers to GDPR or General Data Protection Regulations, this means the European GDPR and the United Kingdom (revised) GDPR. All terms are general unless relating specifically to the UK Revised version.

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2. WHAT PERSONAL DATA WE COLLECT ABOUT YOU

We may collect any of the following data about you:

• Your name
• Your email address
• Your address
• Your phone number
• Your date of birth
• Your business name
• Your financial details
• Any personal data you post on our website
• Data about how you use our website
• Technical data such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website
• Your marketing and communication preferences
• Any other information that you directly provide to us whether through our contact form, over the phone, by email or otherwise, such as when entering a competition or requesting information.

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3. HOW WE MAY USE YOUR DATA

We may use your data in order to:

• Process financial transactions to enable you to purchase our goods our products or services
• Send you customer communications about enhancements to products or services you have bought
• Enable us to perform a contract with you and process orders, respond to enquiries related to the order and deal with complaints
• Reply to any enquiries you make about our products or services
• Send you marketing communications where we are allowed by law to do so
• Personalize your experience on our websites
• Monitor the use of our website and online services
• Ask you to complete surveys or invite you to enter into competitions or prize draws
• Keep records of orders placed and communications in relation to such orders
• Keep records of communications
• Analyze your use of our website and other online services
• Administer and protect our business and website
• Deliver relevant website content and advertisements to you
• Understand the effectiveness of our advertising
• Carry out credit checks
• Bring legal claims against you if you breach a contract or fail to make payment
• Comply with any legal obligations we are subject to or as required by a government authority
• Obtain or maintain insurance policies
• Manage our business
• Obtain professional advice

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4. OUR LAWFUL GROUND OF PROCESSING

Under the General Data Protection Data Regulations, we are only legally able to process your personal data if we have a lawful ground for doing so.

Our lawful grounds of processing are:

• In relation to Customer Data that we have obtained in relation to you placing an order with us that we hold for the purpose of fulfilling that contract, informing you about updates to the product or service and keeping records of the contract, the processing is necessary for the performance of a contract to which you are subject and for our legitimate interests in informing you about updates to the product or service, record keeping and to establish, pursue or defend legal claim as responsible business operations
• In relation to Prospect Data that we have obtained when you enquired about our products or services (whether that be through our website or otherwise) and that we process in order to reply to your enquiry and keep records of this, the processing is necessary in order to take steps at your request prior to entering into a contract and for our legitimate interests in record keeping and to establish, pursue or defend legal claim
• In relation to Prospect Data that we have obtained when you signed up for any of our free resources (if relevant) and that we process in order to send you those free resources (if relevant) reply to your communications about the resources and to keep relevant records, you have given consent to the processing for the purposes of us sending you the free resource and it is in our legitimate interests to reply to your communications and to keep records for our business.
• In relation to Marketing Data that we have obtained when you told us your marketing preferences, when you consented to us sending you details of our products and services, for the purposes of us sending you, but not exclusive to, marketing communications, enabling you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising, the processing is necessary for our legitimate interests which in this case are to study how customers and users use our products/services, to develop them, to grow our business and to decide our marketing strategy.
• In relation to User Data that we have obtained through cookies on our website or other online services for the purposes of operating our website, ensuring relevant content is provided to you, ensuring the security of our website, maintaining back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business, the processing is necessary for the purposes of our legitimate interests which in this case are to enable us to properly administer our website and our business.
• In relation to Technical Data (that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website), we process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
• In relation to your data that we process in order to comply with legal requirements or as required by a government authority, the processing is necessary for compliance with a legal obligation to which we are subject.
• In relation to keeping records, this processing is either necessary for compliance with a legal obligation that we are subject to or for our legitimate interests in responsible business operations or defending, pursuing or establishing a legal claim.
• In relation to obtaining professional advice and insurance, this processing is necessary for our legitimate interests in order to protect and grow our business.

We do not collect any Sensitive Data about you. Sensitive data refers to data that 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.

We do not collect any information about criminal convictions and offences.

We do not carry out automated decision making or any type of automated profiling.

We do not at any time pass, sell or transfer your information to third party data companies.

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5. HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy on this website.

We may receive data from third parties such as analytics providers such as Google based outside of the UK or Europe, advertising networks such as Facebook based outside the UK, such as search information providers such as Google, providers of technical, payment and delivery services, fraud detection agencies and data brokers or aggregators.

We may also receive data from publicly available sources.

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6. MARKETING COMMUNICATIONS  

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may only send you email or text marketing communications if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by emailing us. We also have unsubscribe buttons on the bottom of all of our emails.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc. 

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7. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, accountants, auditors and insurers.
• Government bodies that require us to report processing activities or otherwise disclose your personal data.
• Market researchers and fraud prevention agencies.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

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8. INTERNATIONAL TRANSFERS

We are based in Canada, but, unless we expressly agree otherwise (including through our Terms), we may host, transfer, and process data, including Personal Information, in the United States and in other countries through Webflow and third parties that we use to operate and manage our website.  These countries may have data protection laws that are different from those of your country of residence.

We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of Europe and the UK, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data.

We recognize that the Court of Justice of the European Union ruled in July 2020 that a certification under the EU-U.S. Privacy Shield Framework no longer can serve as the basis by which entities subject to the GDPR export Personal Information to countries whose laws have not been recognized by the European Commission as providing a high level of protection for the information. We therefore rely on adequate provision in accordance with current frameworks and safeguards. The data we transfer is subject to a signed Data Processing Agreement with our hosting company Webflow.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. 

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9. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

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10. 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.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

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11. YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

If you wish to exercise any of the rights set out above, please email us. 

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 is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the relevant authority in your country. These may be found below -

https://edpb.europa.eu/about-edpb/about-edpb/members_en

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12. 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.

UK (RETAINED VERSION) AND EEA GDPR

We care about our customer’s privacy. Because we care, we take steps ensure that all of our products and services are created using the principle of privacy by design.

 All the data we collect is used to make our products and services the best that they can be. In doing this we always ensure your data is protected, and only used where it is necessary for us to provide you with a service or a product. We understand the path your data follows to ensure it is safe, secure and compliant with the necessary data protection law. Following Brexit, the United Kingdom is no longer part of the European Union. We hereby acknowledge the privacy rights of EEA citizens and EEA companies as data subjects under Article 3(2) of the UK Retained GDPR and the European GDPR.

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Exemption of the Representative Requirement.

In accordance with Article 27.2 a), we invoke our right to exemption for appointing an EEA representative as our data processing within the EEA is occasional, does not include, on a large scale, processing of special categories of data as referred to in Article 9(1) or processing of personal data relating to criminal convictions and offences referred to in Article 10, and is unlikely to result in a risk to the rights and freedoms of natural persons, taking into account the nature, context, scope and purposes of the processing 

In accordance with Article 27.2 a) supervisory authorities and persons outside the EEA may contact our Global Privacy Controller on all issues related to processing, for the purposes of ensuring compliance with the GDPR.