Purpose of this privacy policy​

This privacy policy aims to give you information on how Xlinks collects and processes your personal data through our website or otherwise when you interact with us, including any data you may provide when you register your interest in our projects either through our website or through any other means of engagement and/or contact with us.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller​

This privacy policy applies to Xlinks Limited with registered office address at Kingfisher House, 1 Radford Way, Billericay CM12 0EQ and the entities we own or control. When we refer to “we”, “us”, and “our”, we mean any one or more of those data controllers, as appropriate. By “you” or “your” we mean any individual, sole trader and/ or partnership that uses our website, or interacts with us in another way. This privacy policy supplements, or may be supplemented by, other privacy policies you might have from us – but it doesn’t replace them.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Xlinks’ Data Privacy
Kingfisher House
1 Radford Way
Billericay
CM12 0EQ
United Kingdom
Website: https://xlinks.co
Email: [email protected]

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes​

We keep our privacy policy under regular review. This version was last updated on 22 March 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links​

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you​

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Whenever we interact with you, we may collect, use, store and transfer different kinds of personal data about you. The following types of data may be collected from you:

Identity Data	first name, last name, title, date of birth
Contact Data	address, email address and telephone numbers
Technical Data	internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
Profile Data	preferences, feedback and survey responses
Enquiry Data	information you provide when you contact us via: any of our general email accounts (for example, [email protected] or [email protected]) telephone our social media channels, or interact with us at any exhibit, industry or other public event
Usage Data	information about how you use our website
Marketing and Communications Data	your preferences in receiving marketing from us and our third parties and your communication preferences
Recruitment Data	the content of your CV and covering letter where you contact us (directly or indirectly) about a position with us
Other Data	any other information relating to you that you may provide to us

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?​

We use different methods to collect data from and about you including through:

Direct interactions	You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you do one of the following (non-exhaustive list): subscribe to our newsletters and publications; request marketing to be sent to you; or give us feedback or contact us
Automated technologies or interactions	As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Third parties or publicly available sources	We will receive personal data about you from various third parties and public sources, for example (non-exhaustive): Analytics providers such as Google based outside the UK. Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK. Identity, Contact and Technical Data from your social media account if you interact with us via any of our social media channels.

How we use your personal data​

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where you have given your consent, so have specifically provided your personal data for a specific purpose e.g. if you provide your contact details so that we can keep you updated on our projects.
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data​

We have set out in more detail below the purposes for which we will use your data, but in summary:

Project updates	To keep you updated on the Morocco-UK Power Project or other Xlinks’ projects
Communications	To respond to queries, requests for information and complaints
Contract and supply chain opportunities	To engage with you in respect of the opportunity to tender to provide supplied or services to Xlinks and the provision of supplies or services to or by Xlinks
Events	To facilitate your attendance at our events and the management of those events
Recruitment	To explore your suitability for roles within Xlinks, including roles which may suit your skillset but are not the specific role you applied for
Our business purposes	To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) To deliver relevant website content to you To manage complaints To manage our website To use data analytics to improve our website, products/services, marketing, stakeholder relationships and experiences To manage risk To provide for business and disaster recovery To protect our rights, property, and/or safety, our personnel and others To establish, exercise or defend our legal rights, including where we reasonably consider it is in our (or others) legitimate interests To comply with any procedures, law and regulations which apply to us including where we reasonably consider it is in our (or others) legitimate interests to comply.
Managing our relationship with you	To notify you about changes to our privacy policy or any other terms and to ask you to leave a review or take a survey

We may use your personal data for other purposes, but this will be made clear at the point of collection.

If you choose not to provide your personal details to us, we may not be able to deliver the information or services which you have requested and in respect of which we have asked you for that personal data. If the failure to provide the personal data means that we are unable to perform a contract with you, we may have to cancel that contract, but will advise you of the same.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

Cookies

Like other websites, information and data on the Xlinks’ website may be automatically collected through cookies and similar technologies. Cookies are small files placed on website users’ device to distinguish you from other users of the website. This helps us to provide you with a high-quality experience when you browse the website and also allows us to improve the website. We use cookies to analyse the flow of information; customise the services and content; measure promotional effectiveness; and promote trust and safety. 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.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of Your Personal Data

We will share your personal data with the following third parties for the purposes set out in this Privacy Policy:

• Google Analytics, which we use on our website for web analysis
• IT and system administration services
• Data management providers
• Email service providers and communications providers
• Third party agents and contractors for the purposes of the provision of services (for example, professional advisers, legal advisors, and investor and other screening and profile services)
• Our insurers
• Members of the project supply chain
• Providers of social media platforms
• Government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our own legitimate interests in compliance with applicable laws
• In the event that we sell any business assets, purchasers or prospective purchasers of all or part of our assets or our business, and their professional advisers, in connection with the purchase

We will also share your personal data where we have your consent or are otherwise legally permitted to do so.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

We may share your personal data within the Xlinks Group. This may involve transferring your data outside the UK, including to Morocco and Dubai. Many of our external third parties are based outside the UK so their processing of your personal data may involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it to the protection it has in the UK. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data Security

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

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Your right of access	You have the right to ask us for copies of your personal information.
Your right to rectification	You have the right to ask us to correct personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure	You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing	You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing	You have the right to object to the processing of your personal information in certain circumstances.
Your right to data portability	You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

Please contact us at [email protected] if you wish to make a request.

Procedural Matters

No fee usually required: 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. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you: 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.

Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it could 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 and keep you updated.