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  2. Privacy Policy

Privacy Policy

Privacy Policy

Xirocco respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store and protect personal information when you interact with Xirocco, including when you use our website, contact us, engage with our services or otherwise communicate with us.

01

Who We Are

Xirocco provides AI and technology strategy consulting services supported by the Xirocco and Maeros AI platforms. For the purposes of applicable data protection law, Xirocco may act as a data controller where we determine how and why personal data is processed. In some customer engagements, Xirocco may also act as a data processor where we process personal data on behalf of a customer.

02

Information We May Collect

Depending on how you interact with Xirocco, we may collect information including:

  • Your name

  • Job title or role

  • Organisation name

  • Business contact details

  • Email address

  • Telephone number

  • LinkedIn or other professional profile information where provided

  • Information contained in enquiries or correspondence

  • Information relating to meetings, demonstrations or commercial discussions

  • Technical information relating to your use of our website

  • Information required to provide consulting, platform or support services

We only seek to collect information that is relevant to the purpose for which it is being used.

03

How We Use Personal Information

We may use personal information to:

  • Respond to enquiries

  • Communicate with prospective and existing customers

  • Arrange meetings, demonstrations and consultations

  • Provide consulting and technology services

  • Manage customer and partner relationships

  • Support contractual and commercial activities

  • Manage invoicing and administration

  • Improve our services and website

  • Protect our systems and information

  • Meet legal, regulatory and compliance obligations

  • Maintain appropriate business records

We do not sell personal data.

04

Lawful Basis for Processing

Where required by UK data protection law, Xirocco processes personal data on an appropriate lawful basis. Depending on the circumstances, this may include:

  • Consent

  • Performance of a contract

  • Steps taken before entering into a contract

  • Compliance with a legal obligation

  • Legitimate interests

Where we rely on legitimate interests, we consider the interests and rights of the individuals whose data is being processed.

05

Customer Data

Where Xirocco processes information provided by a customer in connection with our services, the respective responsibilities of Xirocco and the customer will depend on the nature of the engagement.

In some circumstances, the customer will act as the data controller and Xirocco will act as the data processor. Where this applies, Xirocco processes the information in accordance with the relevant contractual arrangements and customer instructions.

06

AI and Customer Data

Xirocco does not use customer data to train general-purpose AI models. Where AI capabilities are used within Xirocco or Maeros AI, customer-authorised data is intended to support that customer's own analysis and decision-making. Customer information is not used to train shared general-purpose models for unrelated customers.

07

How We Protect Personal Data

Xirocco applies appropriate technical and organisational measures designed to protect personal data against:

  • Unauthorised access

  • Accidental loss

  • Misuse

  • Alteration

  • Disclosure

  • Destruction

Our security approach includes secure development practices, access controls, cloud infrastructure safeguards, supplier management and operational security measures. Further information is available on our Security & GDPR page.

08

Data Hosting and International Transfers

Xirocco uses cloud and technology service providers to support the operation of its business and services. Customer data associated with the Xirocco platform is hosted in the United Kingdom.

Where personal data is transferred internationally, Xirocco seeks to ensure that appropriate safeguards and contractual arrangements are in place where required by applicable data protection law.

09

Sharing Personal Information

We may share personal information with selected third parties where this is necessary for legitimate business purposes. These may include:

  • Cloud and technology providers

  • Professional advisers

  • Business administration providers

  • Customer relationship and communication services

  • Relevant partners involved in delivering an agreed engagement

We expect service providers that process personal data on our behalf to handle it appropriately and only for authorised purposes. We may also disclose information where required by law or where necessary to protect our legal rights.

10

Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including where necessary to meet legal, accounting, contractual or reporting requirements.

Retention periods may vary depending on the nature of the information and the purpose for which it is processed.

11

Your Data Protection Rights

Depending on the circumstances and applicable law, you may have rights including:

  • The right to access personal data held about you

  • The right to request correction of inaccurate information

  • The right to request deletion of personal data

  • The right to restrict processing

  • The right to object to certain processing

  • The right to data portability where applicable

  • The right to withdraw consent where processing is based on consent

These rights are subject to the conditions and exemptions provided by applicable data protection law.

12

Marketing Communications

Where Xirocco sends marketing or business-development communications, we aim to do so in accordance with applicable law. You may ask us to stop sending marketing communications at any time. We may continue to send non-marketing communications where these are necessary for an existing business relationship, contractual matter or legal obligation.

13

Cookies and Website Technologies

The Xirocco website may use cookies or similar technologies to support site functionality, security, performance and analytics. Further information about the cookies used by the website is available in our Cookie Policy.

14

Links to Other Websites

The Xirocco website may contain links to third-party websites. Xirocco is not responsible for the privacy practices or content of external websites. You should review the privacy information provided by those organisations when visiting their websites.

15

Children's Data

Xirocco's website and services are intended for business and professional use. They are not intended to be directed at children.

16

Information Commissioner's Office

Xirocco is registered with the UK Information Commissioner's Office. ICO registration number:

ZB178559

You also have the right to raise a concern with the Information Commissioner's Office if you believe your personal data has not been handled appropriately.

17

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business, services, legal obligations or data-processing practices. The current version published on the Xirocco website should be treated as the applicable version.

18

Contact Us

If you have questions about this Privacy Policy, how Xirocco handles personal data, or wish to exercise a data-protection right, please contact us through the Xirocco website.

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Credentials & Certifications

Crown Commercial Service supplierXirocco ISO 27001 certificationInformation Commissioner's Office registrationGDPRNatWest Accelerator

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