Privacy Policy
PUBLISHED: DECEMBER 16, 2021
Thank you for choosing to be part of our community at XRS Group Ltd (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices, please contact us at info@xrs.com.
This privacy notice describes how we may use your information if you:
- VISIT OUR WEBSITE AT [HTTPS://WWW.XRS.COM]
- CREATE AN ACCOUNT OR PURCHASE A TRADING CHALLENGE ON OUR PLATFORM (WHICH MAY BE PROVIDED THROUGH A THIRD-PARTY SERVICE PROVIDER)
- ENGAGE WITH US IN OTHER RELATED WAYS, INCLUDING SALES, MARKETING, OR EVENTS
In this privacy notice, if we refer to:
- “WEBSITE”, WE ARE REFERRING TO ANY WEBSITE OF OURS THAT REFERENCES OR LINKS TO THIS POLICY
- “SERVICES”, WE ARE REFERRING TO OUR WEBSITE AND RELATED SERVICES, INCLUDING COMMUNICATIONS, CUSTOMER SUPPORT, AND PLATFORM ACCESS RELATED TO OUR SIMULATED TRADING EVALUATION OFFERING
The purpose of this privacy notice is to explain, as clearly as possible, what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
IN SHORT: We collect personal information you provide to us.
We collect personal information that you voluntarily provide to us when you register, purchase a challenge, contact us, request information, subscribe to marketing communications, or otherwise interact with our Services.
The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include:
- Names
- Email addresses
- Phone numbers
- Billing address (where relevant)
- Contact preferences
- Customer support communications
- Other similar information you choose to provide
Payment data
In Short: Payment details are handled by our payment providers.
If you make purchases, your payment may be processed by third-party payment processors (for example, Stripe or other providers used by our platform provider). We do not store full card details on our Website. Payment processors handle your payment information in accordance with their own privacy notices.
Information automatically collected
In Short: Some information, such as IP address and browser/device characteristics, is collected automatically.
We automatically collect certain information when you visit, use, or navigate our Website. This information does not reveal your specific identity but may include device and usage information, such as:
- IP address
- Browser and device characteristics
- Operating system
- Referring URLs
- Country / approximate location (based on IP address)
- Information about how and when you use our Website
- Diagnostic and performance information
This information is primarily needed to maintain the security and operation of our Website and for internal analytics and reporting.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information based on legitimate business interests, performance of a contract, legal obligations, and/or your consent.
We may use personal information collected via our Services for the following purposes:
- To facilitate account creation and logon processes (where applicable)
- To provide and administer access to our Services, including customer support
- To send administrative information such as updates to our terms, policies, or service notices
- To protect our Services including fraud monitoring and security
- To enforce our terms, policies, and legal rights
- To respond to legal requests and prevent harm
- To process orders and manage purchases (typically via our platform and
- payment providers)
- To request feedback and improve our Services
- To send marketing and promotional communications, where permitted and in accordance with your preferences (you can opt out at any time)
- For internal business purposes, such as data analysis, usage trend identification, and improving Website performance and user experience
We may use and store information in aggregated and anonymised form so that it is not associated with individual users.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We share information only with your consent, to comply with laws, to provide Services, to protect rights, or to fulfil business obligations.
We may share your information in the following situations:
Service providers (processors)
We may share your information with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf, such as:
- Website hosting and infrastructure
- Analytics services
- Customer support tools
- Email delivery services
- Payment processors
- Advertising and marketing partners
- Platform provider(s) supporting account access, challenge administration, and dashboards
These providers are required to protect your information and only process it on our instructions.
Business transfers
We may share or transfer information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
Legal obligations and vital interests
We may disclose your information where required by law or where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, threats to safety, or illegal activities.
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short: We share personal information with categories of third parties that help us run our Services.
Categories may include:
- Payment processors
- Website hosting providers
- Data analytics providers
- Email delivery providers
- Advertising networks and marketing partners
- User authentication and account tools
- Customer support tools
- Platform service providers used to operate the simulated evaluation environment
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5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information as long as necessary for the purposes described, unless a longer period is required by law.
We keep personal information only for as long as necessary to fulfil the purposes outlined in this privacy notice, unless a longer retention period is required or permitted by law (for example, tax, accounting, or legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will delete or anonymise it. If deletion is not possible (for example, because data is stored in backups), we will securely store and isolate it until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We use organisational and technical security measures to protect your information.
We have implemented appropriate technical and organisational measures designed to protect personal information. However, no electronic transmission or storage system can be guaranteed to be 100% secure. You use our Services at your own risk and should access them in a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to individuals under 18.
Our Services are not intended for individuals under 18. If we learn that we have collected personal information from someone under 18, we will take reasonable steps to delete it. If you believe we may have collected such information, contact us at info@xrs.com
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In the UK and EEA, you have rights to access and control your personal information.
Depending on your location, you may have rights under applicable data protection laws, including:
- The right to request access to your personal data
- The right to request correction or deletion
- The right to restrict processing
- The right to object to processing
- The right to data portability (where applicable)
- The right to withdraw consent at any time (where processing is based on consent)
To exercise these rights, contact us at info@xrs.com
We will respond in accordance with applicable law.
If you are in the UK and believe we are unlawfully processing your personal information, you have the right to complain to the UK Information Commissioner’s Office (ICO). If you are in the EEA, you may complain to your local data protection authority.
Marketing communications
You can opt out of marketing emails at any time by clicking the unsubscribe link in our emails or by contacting us at info@xrs.com
We may still send non-marketing messages necessary to provide our Services.
9. COOKIES AND TRACKING TECHNOLOGIES
We may use cookies and similar tracking technologies to access or store information for Website functionality, analytics, and marketing attribution. You can control cookies through your browser settings and, where implemented, our cookie preference tool.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most browsers offer a Do-Not-Track (“DNT”) feature. There is currently no uniform standard for recognising DNT signals. As such, we do not currently respond to DNT browser signals. If standards change, we will update this notice.
11. INTERNATIONAL DATA TRANSFERS
Our Website and Service providers may process data in the United Kingdom and other countries. Where personal data is transferred internationally, we take steps to ensure appropriate safeguards are in place as required by applicable law.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we update this notice as necessary to remain compliant
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and will be effective when posted. We encourage you to review this policy regularly.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact us at info@xrs.com
or by post to:
XRS Group Ltd
6th Floor, 299 Oxford Street
London, United Kingdom, W1C 2DZ
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
To request to review, update, or delete your personal information, please contact us at info@xrs.com
We may need to verify your identity before responding.
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