InExchange respects your privacy. This Privacy Statement outlines your rights to privacy and our commitment to safeguarding your personal data. InExchange ambition is to be fully transparent in our privacy practices and the choices you can make regarding your personal data that is processed by InExchange.
InExchange is a European corporation, with legal entities, business processes, management structures and technical systems that cross borders. InExchange delivers software and services to private and public businesses (Customers) in Europe. InExchange head office is located in Skövde. All InExchange companies are located in the EU/EEA area, and are therefore subject to European data protection- and privacy regulations and directives. Our privacy policies and guidelines respect and comply with EU-directive 95/46/EC, in addition to privacy legislation in those countries in which we operate. We also work continuously on adapting to the new General Data Protection Regulation and EU/US Privacy Shield framework for data transfers to the US. All major decisions regarding privacy in InExchange are made at a corporate level.
Scope and acceptance
This Privacy Statement applies to all business processes in InExchange and to all InExchange websites, domains, mobile solutions, cloud services and communities as well as InExchange- branded websites and third party social networks (e.g. Facebook) (InExchange Sites). Any specific appendices for our cloud services will be found in the Terms of Service or equivalent for the service in question.
The Statement provides information about data processing carried out by InExchange when InExchange determines the purpose and means of the processing (InExchange as data controller), and data processing we do on behalf of our Customers based on their instructions (the Customer as data controller and InExchange as data processor).
Personal data is information that can identify you as a person, such as an email address, street address or phone number. Processing your personal data is necessary for us to serve you or our Customers. By providing us with your personal data, you accept the practices and terms described in this Privacy Statement. Please do not use InExchange Sites or provide your personal data if you do not agree.
Whose data we process
InExchange process data about jobseekers, contact persons and software users among our Customers, including persons representing potentially new Customers that approach us via InExchange Sites or other channels. Our statement in these regards is to be found in the data controller section.
We also process data about our Customers’ employees and other persons’ data of which the Customer controls. Our statement in these regards is to be found in the data processor section.
In this Statement data subjects may also be referred to as persons or you.
InExchange as a data controller
When a InExchange subsidiary determines the purpose and means of processing your data, this company act as data controller. InExchange control personal data that we collect in the context of you being a jobseeker, you are employed by a Customer that has or may have a business relation to InExchange, or you declare that you want to receive information from us based on your own or your employer’s interests. When you represent a Customer of InExchange, your rights are the same as if you were a private person only representing yourself.
Why we process your personal data
To manage our Customer relations in general and to meet our Customer commitments, InExchange requires some information about you in your role as Customer contact person or user of a service. Our aims with this are:
a) Provide offers on programs and services that Customers or prospective customers have requested
b) Inform about and present program and service offers that are closely related to the services and programs the Customer already uses
c) Perform deliveries in accordance with a customer agreement
d) Offer support to users of our programs and services
e) Improve the quality of our programs, services and InExchange Sites
f) Detect and prevent security threats and perform maintenance and debugging
g) Prevent abuse of our programs and services
h) Communicate information that is relevant for our deliveries in particular and our customer relations in general
i) Process orders, invoicing, payments and other financial follow up of Customers
j) Payment of programs and services purchased through InExchange Sites
Processing according to the above listed purposes (a to j) is necessary for us to manage our customer relations. Therefore InExchange do not, as additional ground ask for your consent to process your personal data. We do not consider that the processing disadvantages you in any way.
In addition, we will also collect information about you as a contact person or user of a service, for the following purposes:
k) To manage your access to our web-based services (cloud services)
l) To promote new products and services
If you are a jobseeker, we gather information in order to:
m) Analyse your skills and background
n) Evaluate your potential as a InExchange employee
The basis for InExchange’s processing of personal data for the above purposes (k to n) is based on your voluntary consent. Your consent may be given freely on InExchange Sites when applicable. Please note that the collection of individual personal data is required in order to gain user access to many of our programs and services and also to access the information you have requested.
To protect your security and ours we will also store information about you when you visit our premises. You will be informed of your rights in this context when you register in our electronic visitor system.
How we collect your personal data
In general, InExchange collects data directly from you or other persons linked to the Customer company where you are employed. These persons may be a manager or colleague. If the Customer you work for purchases InExchange programs and services via a InExchange partner company, we may collect information about you from the partner company.
In some cases, we may also collect information about you from other legitimate sources if you have given your consent that the party collecting the personal data may share this with others. These sources may be third party data aggregators, InExchange’s marketing partners, public sources or third party social networks. InExchange will be able to combine personal data about you obtained from one source with data obtained from another source. This gives us a more complete picture of you as contact person, which also gives us the possibility of serving you in a more relevant way with a greater degree of personalization.
Automatic data collection tools
InExchange use a variety of technologies to collect information about your movements on the web as well as interest and preferences you freely have made available.
Cookies are small text files that contain a string of characters and uniquely identify a browser. They are sent to a computer by website operators or third parties. Most browsers are initially set up to accept cookies. You may be, however, able to change your browser settings to cause your browser to refuse third-party cookies or to indicate when a third-party cookie is being sent. If you would like to know more about cookies and how they work, please visit www.allaboutcookies.org.
Marketing Automation Tools
InExchange uses digital marketing software provided by Oracle that employs cookies in order to recognize a return visitor as a unique user. The cookies placed by this software are readable only by the vendor of the software, and cookies cannot access, read or modify any other data on your computer. We do link the information we store in cookies to any personally identifiable information you submit while on our site.
Google Analytics: This cookie allows us to see information on user Website activities including, but not limited to page views, source and time spent on a Website. The information is depersonalized and is displayed as numbers, meaning it cannot be tracked back to individuals. This will help to protect your privacy. Using Google Analytics we can see what content is popular on our Website, and strive to give you more of the things you enjoy reading and watching.
Google Analytics Remarketing: Places cookies on your computer which means that after you leave our website, Google can show you advertisements about InExchange that you might be interested in, based on your previous behaviour on our website. This information is not personally identifiable.
Google AdWords: By using Google AdWords code, we are able to see which pages helped lead to contact form submissions. This allows us to make better use of our paid search budget. This information is not personally identifiable.
Google Adwords Remarketing: Places cookies on your computer which means that after you leave our website Google can show you advertisements about InExchange that you might be interested in, based on your previous behaviour on our website. This information is not personally identifiable.
You can prevent the information generated by the Google cookie about your use of our Sites from being collected and processed by Google in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser. This Add-on is available at http://tools.google.com/dlpage/gaoptout.
What personal data we process
The type of data that InExchange process about you may be:
Your own and the Customer’s contact details such as name, address, telephone number and email.
Information about date of birth, age and gender
Employment information about you at the customer company such as job title, position including preferences and interests in professional context
Feedback, comments or questions about InExchange as a supplier, or concerning our programs and services
Photos or video of you recorded at our premises
Content you have uploaded such as photos and video
Unique user information such as login ID, username, password and security question
Financial information such as credit card information
Traffic information as provided by your web browser such as browser type, language and the address of the website from which you arrived and other traffic information such as IP address
Clickstream behaviour such as which links you click and when
Other personal data contained in your profile on third party social networks (Facebook etc.)
We may also in some cases compare a collected IP address with a geographic map service to derive your general location.
If you make a post, comment or similar on any public forum or InExchange Site, such information can be read and used by anyone with access to site and used for purposes over which neither InExchange nor you have control. InExchange is not responsible for any information you submit on such forums or InExchange Sites. InExchange will not post any comment, testimonial or similar made by you without your prior consent.
As data controller, InExchange do not process sensitive personal data about you.
How we share your personal data
As InExchange consists of many different companies, there is a great likelihood that a Customer will conduct business with more than one InExchange company. It is important for us that we provide the best possible customer service and overall experience. In order to maintain a complete overview and insight into which Customers have relations with the various companies in the group, we will therefore share your data among these companies. The aim of this is to ensure that you can access the relevant information on time and that you are not contacted more often than is necessary for you or for InExchange.
InExchange does not share your personal data with third parties who intend to use the data for marketing purposes if you have not given your consent to this.
InExchange may share your personal data with third parties for other purposes but only in the following contexts:
InExchange may share your personal information with our partners in the event this is legitimate from a business perspective. For example, if you purchase a program or service on behalf of your employer that we provide through one of our certified partners.
The police and other authorities may demand the handover of personal information from InExchange. In these cases, InExchange will only hand over the data if there is a court order to do so.
In connection with mergers, acquisitions or divestiture of all or parts of InExchange’s business, the acquiring entity as well as its consultants and InExchange’s will obtain access to data managed by the InExchange entity/entities involved and this may in some cases include personal data. In which case such external parties will enter into a NDA with InExchange, which will also cover potential disclosure of personal data.
Right to opt-out of marketing communications
You have the right to opt-out of receiving marketing communications from InExchange and can do so by:
(a) Following the instructions for opt-out in the relevant marketing communication,
(b) Change your op-in/opt-out preferences under the relevant edit account section if you have an account with InExchange, or
(c) Contacting us via e-mail
Please note that even if you opt-out from receiving marketing communications, you may still receive administrative communications from InExchange, such as order confirmations and notifications about your account activities (e.g. account confirmations and password changes).
Access and rectification
You have the right to request a copy of your personal data. You may send us a request for this.
You also have the right to request that InExchange correct any inaccuracies in your personal data. If you have an account with InExchange for a InExchange Site, this can usually be done through the appropriate ”your account” or ”your profile” section(s) on the InExchange Site (if available) or inside your InExchange cloud service. To manage subscription settings for InExchange Newsletters, please click the “Manage my subscription” link at the bottom of the emails you receive. Alternatively, you can send us a request to rectify your data.
Data security and retention
How we keep your personal data secure
InExchange takes the trust you place in us seriously. InExchange is committed to prevent unauthorized access, disclosure or other deviant processing of your data. Further, InExchange is committed to ensure proper use of the information, to maintain data integrity and to secure data availability. As part of our commitment, we utilize reasonable and appropriate physical, technical, and administrative procedures and measures to safeguard the information we collect and process. InExchange has implemented a number of security measures, including:
Secure operating environments – InExchange stores your data in secure operating environments that are only accessible to InExchange employees and subcontractors on a need-to-know basis. InExchange also follows generally accepted industry standards in this respect.
Encryption of payment information – InExchange uses industry-standard encryption to provide protection for sensitive financial information, such as credit card information, sent over the Internet (e.g., when you make payments through InExchange’s online stores).
Prior authentication for account access – InExchange requires its registered users to verify their identity (e.g. login ID and password) before they can access or make changes to their account in order to prevent unauthorized access.
Please note that these protections do not apply to the personal data that you choose to share in public areas such as community websites.
How long we store your personal data
InExchange will only retain your personal data for as long as necessary for the stated purpose, while also taking into account our need to answer queries or resolve problems and to comply with legal requirements under applicable laws.
This means that we may retain your personal data for a reasonable period after your last interaction with us. When the personal data that we collect is no longer required in this way, we destroy or delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymized.
InExchange as a data processor
InExchange provides many different services to our Customers. These services involves processing of the Customers’ data and may include processing of personal data. The purposes of this processing is determined by our Customers and not by InExchange. The Customer is then the data controller for the data subject’s data. InExchange do in such cases act as data processor and process the data on behalf of and according to instructions given by the Customer. When acting as data processor, InExchange is in accordance with the requirements in applicable data protection legislation always committed to enter into a data processing agreement (DPA) with the Customer. The Customer has agreed and guaranteed that:
The Customer is the owner of or otherwise has the right to transfer the data to InExchange for processing and that he has the responsibility for the accuracy, integrity, content, reliability and legality of the personal data
It is the Customer’s duty as data controller to notify, to the extent required by applicable law, the relevant supervisory authorities and/or the data subject in the event of any breach or unauthorized disclosure of personal data
When acting as data processor, InExchange is responsible for providing technical and organizational security measures in order to safeguard your privacy on behalf of our Customer – the data controller.
As data processor, InExchange will not process personal data in any other manner or for any other purpose than as authorized in the agreement with the data controller.
Data subjects having questions, comments, claims or any other issues regarding their personal data that InExchange is data processor for, must submit these to the data controller. As data processor, InExchange will not give any data subjects access to their personal data without instructions given by the data controller to do so. If governmental authorities or the police request disclosure of personal data, InExchange will promptly notify the data controller and we will disclose such data only to comply with a court order.
InExchange will provide non-public information about internal systems and routines for data processing to Customers and collaboration partners upon request. This may be contingent upon a non-disclosure agreement.
Subcontractors and export of personal data
In some cases, InExchange will use subcontractors to process personal data, and we may export your or our Customers data outside the EU. These subcontractors are typically vendors of cloud services or other IT hosting services. When using subcontractors, InExchange will always enter into a data processing agreement (DPA) in order to safeguard your privacy rights and/or to fulfil our obligations towards our Customers.
If the processing of data is performed outside of the EU, we will make sure that the DPA is based on the EU Standard Contractual Clauses or that the data importer is certified according to the EU/US Privacy Shield framework, if located in the US. In such cases, we will also inform our Customers about the export of data. InExchange is not responsible for providing such information to data subjects whose data is controlled by our Customers.
Changes to this Statement
If we modify our Privacy Statement, we will post the revised statement here, with an updated revision date. We encourage you to review the Statement regularly. If we make significant changes to our Statement that materially alter our privacy practices, we may also notify you by other means, such as sending an email or posting a notice on our corporate website and/or social media pages prior to the changes taking effect.
The last update of this Privacy Statement was September 1st 2016.
How to contact us
We value your opinion. If you have any comments or questions about our Privacy Statement, any unresolved privacy or data use concerns that we have not addressed satisfactorily, or concerning a possible breach of your privacy, please send them to email@example.com. You can also send it in writing to InExchange Data Protection Manager, Box 133 541 23 Skövde.
We will handle your requests or complaints confidentially. Our representative will contact you to address your concerns and outline the options regarding how these may be resolved. We aim to ensure that complaints are resolved in a timely and appropriate manner.