Privacy Policy
X Cyber Group Ltd is the controller responsible for your personal data. We collect and process your personal data when you provide your email address to us by entering it into Protect.
This privacy notice provides information on how we collect and process your personal data when you visit our website.
Our website privacy policy contains more detailed information about our data processing (including about data security, data retention and lawful processing bases) and you should read that in conjunction with this privacy notice.
Who we are
X Cyber Group Ltd is the controller and responsible for your personal data and is referred to as “we”, “us” or “our” in this privacy policy.
The data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data.
- Contact Data.
- Technical Data.
- Profile data.
- Usage Data.
In sum, you provide us with an email address which we Protect uses as a search term when looking for your data on the Internet. In order to check that you are entitled to use the email address you nominate, we will verify your control of it by sending verification codes.
When we search the internet looking for your data, we will flag to you instances where your data is found online. The information we find online may well include some or all of the data types listed above.
Although Protect will flag to you that your data is visible on the internet, we do not control the internet and Protect cannot remove it for you. Therefore, if you cease to use Protect, we will delete the data you have given us, but we cannot delete data which is openly available on the internet.
How we use your personal data
We will only use your personal data for the purpose for which we collected it which includes the following:
- To register you as a new customer.
- To process and deliver your Protect account.
- To manage your relationship with us.
- To recommend products or services which may be of interest to you.
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example when you nominate an email address for Protect to use as a search term when scanning the internet.
- Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
How we share your personal data
We do not share your personal data with any 3 rd parties.
International transfers
We may transfer, store and process your personal data outside the UK if you are located outside the UK permanently or because you are travelling.
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. Protect processing occurs automatically and only you can see the results. You are responsible for ensuring that you keep your login details safe and secure.
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
How long will you use my personal data for?
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. However, in this case our contract is with your employer or other service provider who pays for Protect and therefore will not keep any information about you.
You can ask us to delete the data you have provided to us. However, the quickest and easiest option is for you to delete the email address yourself on Protect. That will immediately cause all processing to cease.
Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a "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. In practice, this information is always available to you via the Protect webpage.
- Request correction of the personal data that we hold about you. However, you nominate and enter your email address, and the search results simply flag information we can see on the Internet and which we will not have the ability to correct at source.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 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. In practice, you can quickly and easily object to processing or erase your data via Protect.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. However, in almost all cases we process your data based on your consent, which can be withdrawn at any time by deleting your nominated email address.
- You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes. However, we do not process or share your data for marketing purposes.
- Request the transfer of your personal data to you or to a third party. You are permitted to show or copy the Protect results page and give it to a third party.
- Withdraw consent at any time where we are relying on consent to process your personal data. You can do this by simply deleting your nominated email address in Protect. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we will not be able to provide any Protect services to you.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- Where our use of the data is unlawful, but you do not want us to erase it;
- 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
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
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
In most cases, you can exercise your rights immediately, and in full, via the Protect webpage. 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.
Contact details
If you have any questions about this privacy notice or our data protection practices, please contact privacy@discover-protect.com.
You can also complain to the ICO if you are unhappy with how we have used your data.
ICO offer live chat via their website: https://ico.org.uk/make-a-complaint/. The ICO’s address and telephone number are:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: +44 (0)303 123 1113