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Xpedite B.V. (part of ExpertCollege Holding) processes personal data for the purpose of providing our products and services, including offering e-learning modules on the use of Artificial Intelligence (AI) tools within organisations. In doing so, we act in accordance with the General Data Protection Regulation (GDPR) to ensure that your data is processed carefully, and your privacy is protected.

When client organizations purchase Xpedite services, the client determines the purposes and means of processing. Therefore, it acts as a Controller, whereas Xpedite acts as a Processor, carrying out processing on behalf of the client organization.

In this privacy policy, we would like to inform you about our policies, how Xpedite handles your personal data and how we fulfil our duties as Controller or Processor. We would also like to make you aware of the rights you have when Xpedite processes your personal data.

Should you have any questions after reading this privacy policy, or if you have feedback on how we handle your personal data, please refer to the information on how to contact us about this at the bottom of this page.

1. What kind of personal data do we process?

1.1 Xpedite acting as a Controller

When we process personal data for marketing purposes

Marketing through Xpedite affiliates: When you provide your personal data to ExpertCollege Holding companies and were informed of their data collection practices through their respective privacy policies, or otherwise agreed to share your personal data with their partners and affiliates, we may collect this data from these companies for the purpose of direct marketing.

When we collect data from companies affiliated with ExpertCollege Holding, we will only collect data necessary for our marketing purposes, namely:

  • Your first and last name;
  • Your email address;
  • Your profession/title.

We will always balance our interest in advertising our products and services against your interest in protecting your personal data, as well as the benefit you might derive from receiving marketing offers relevant to your field. We will ensure that you have the option to unsubscribe from such emails at any time.

Inbound marketing: We also aim to attract customers by creating interesting content and user experiences tailored to your needs. When you use Xpedite content and have given permission for cookies to be placed on your device, we can track which pages you view and what content you use.

If you wish to take up an offer, such as access to content, manuals and webinars, we will collect your contact details (name, email address, professional details) in exchange for access to the content. By accessing, downloading, or using the content, you agree to the collection of your personal data.

When you fill in a form in response to a content offer and provide contact details/personal information, we will link your previous page visits to your contact details in our system (only if you have consented to tracking cookies). We will use this information to send you information about our products/services that we think may be relevant to you.

If you no longer wish to receive this information from us, you can unsubscribe. In that case, we will remove your details from our mailing list.

We use HubSpot to plan and execute our marketing activities. More information about this platform is available here.

Outbound marketing: We promote Xpedite to carefully selected companies that we think will benefit from the product. To do this, we collect the following data from public sources:

  • Initials and surname (including affixes) of the director/owner of the company.

We approach potential leads directly or through a partner company that only processes data on behalf of Xpedite. We have signed a processor agreement with this company and guarantee your rights as a data subject under the GDPR.

We will always balance our interest in promoting our products with your right to the protection of your personal data. If you indicate that you do not wish to receive calls from us, we will no longer contact you and delete your data from our systems.

Cookies and tracking

A cookie is a small file, often containing unique identifiers, that is placed on your device temporarily or for a longer period to allow websites to record your browsing behaviour and store information. Different types of cookies may be used, depending on the desired duration, purpose and the party placing them.

Duration

  • Session cookies: these cookies store your information only while you are using the website and are deleted when the website is closed.
  • Permanent cookies: these remain on your browser or device even after you close your browser (for instance to allow a website to remember your password).

Purpose

  • Strictly necessary cookies: these enable websites to function properly and are related to services specifically requested by you as a user.
  • Functional or preference cookies: these allow websites to remember choices you have made in the past, such as your preferred language settings. They can also remember your login details, allowing you to log in automatically.
  • Analytical or statistical cookies: these collect information about how users interact with websites for statistical purposes, and to improve content and features.
  • Marketing or tracking cookies: these collect data to build user profiles for promotional purposes or to track the user on a specific website or across different websites.

Party placing the cookies

  • First-party cookies: these cookies are placed directly by the websites you visit.
  • Third-party cookies: these cookies are placed by websites other than the ones you are visiting.

Cookies used by Xpedite

Strictly necessary cookies: these cookies are placed for the following purposes:

  • to ensure the website works as expected;
  • to see which user is logged in;
  • to save modules;
  • to save course IDs.

These are first-party cookies (placed by Xpedite) that will remain on your device for as long as necessary with regard to the above purposes.

Functional cookies: these cookies are placed on your device for the following purposes:

  • to save your language preferences;
  • to save your login details.

These are first-party cookies that will remain on your device for as long as necessary with regard to the above purposes.

Functional cookies can be turned off at any time in the cookie settings.

Analytical cookies: these cookies are placed on your device for the following purposes:

  • marketing purposes: measuring ad reach;
  • measuring website traffic;
  • measuring how users interact with certain features and how long they stay on certain pages.

We use Google Analytics in accordance with the guidelines of the Dutch Data Protection Authority:

  • we have a processing agreement with Google;
  • we anonymise IP addresses;
  • data sharing with Google is disabled;
  • data sharing with Google for advertising purposes is disabled;
  • the user ID function is disabled.

You can always disable analytical cookies in the cookie settings. They are first-party cookies that are deleted after 12 months.

Tracking cookies: these cookies are placed on your device for the following purposes:

  • tracking visitors anonymously before they become contacts;
  • tracking page views;
  • linking page views to existing or new contacts.

Tracking cookies are placed only after you have given your consent. You can withdraw your consent at any time in the cookie settings. Tracking cookies are first-party cookies that are deleted after 12 months.

When ordering products on our website

When you purchase e-learning modules through our website, we also collect data needed to process your payment and in some cases for sending products by post. In these cases, we will request and process additional data, namely:

  • Your address details;
  • Your billing information;
  • Your payment method;
  • Your phone number.

1.2 Xpedite acting as a Processor

When a client organization (Controller) purchases Xpedite services

When your employer (in its capacity as a Controller of your personal data) purchases Xpedite services, we require certain employee information to provide our services. We process the following personal data of employees:

  • First and last name
  • Email address
  • Phone number
  • Job title
  • Department
  • Role
  • Insights (feedback)

When you study using our e-learning modules, we also keep records of your study progress. We record which modules you have started and completed. Our system also records the answers you give in the e-learning modules. This happens automatically and is necessary to determine your score, which questions and topics should or should not be brought to your attention in more detail, and to show you your progress. During this process, we therefore record the following personal data:

  • Study progress data.

Contact with our customer service 

When you contact our customer service, you will be asked to share personal data so that we can verify your identity and help you with your account. We will never ask for unnecessary data and will instruct you to send any additional information to our Data Protection Officer to ensure the confidentiality of your data. We collect this data to fulfil our obligations to you, including providing customer service.

If you experience technical problems related to your account, we may need to log into your account to resolve these issues. No data will be downloaded from your account during this process.

Calls to our customer service may be recorded for training purposes. By calling our customer service, you consent to your conversation being recorded. If you do not want your conversation to be recorded, you can end the call and contact us via email.

2. Why do we process this personal data?

When client organizations (Controllers) purchase Xpedite services, we need to process certain categories of employee personal data to provide our services. Xpedite does not process more data than necessary for the purposes determined by the Controller. The data processing purposes arising from our product and service offerings are:

  • Registering user accounts;
  • Recording study progress in our e-learning modules;

3. Will your personal data be shared with third parties?

Xpedite shares your data with third parties for the following purposes:

  • if this is necessary for the performance of the agreement between Xpedite and the Controller, or if you have given your consent;
  • cross-marketing campaigns in collaboration with ExpertCollege Holding affiliates, to market products and services that we believe are relevant to your needs. In these cases, we will only share strictly necessary data (name, email address and profession/title). We will share your data only after verifying that the affiliated company fully complies with data protection legislation. We will only share personal data you have provided to us directly on our website/through our contact forms (when we act as a Controller).

4. How long will your data be stored?

If a legal time limit exists for the processing of certain types of personal data, Xpedite will store this personal data for at least as long as required by law and/or no longer than the legally prescribed time limit.

However, no such legal time limit exists for most of the personal data Xpedite processes. When we process data on behalf of client organizations, personal data from your account, including study progress data, will be stored in your account for the duration of the agreement between Xpedite and the client organization (Controller) and for as long as the Controller wishes us to store it after the agreement has ended, and will then be irrevocably deleted.

If you are no longer employed by the Controller and wish to have your data deleted, please contact the Controller. We will do our best to assist the Controller in respecting your right to have your personal data deleted.

If the agreement between Xpedite and the Controller has ended or you are no longer employed by the Controller, Xpedite will assist the Controller in respecting your right to data portability.

Data for marketing and commercial purposes will be stored as long as you are registered as a customer of Xpedite, or until we have determined that you are no longer a (potential) customer of our products or services.

5. Data transfer to countries outside the EEA

We may outsource certain tasks (such as providing customer and back-office services) to our affiliates outside the European Economic Area (EEA), namely in the Philippines.

We have taken appropriate measures to ensure that the protection your data enjoys in the EEA also applies if your data is accessed elsewhere. Xpedite and its affiliates have carried out a Data Protection Impact Assessment (DPIA) and signed standard contractual clauses approved by the European Commission. If you would like to see a copy of these provisions, please contact our Data Protection Officer at the address below.

All your personal data is stored securely on servers within the EEA and can only be accessed remotely by our affiliates for customer service, technical support and back-office purposes.

When Xpedite acts as a Processor, we will only share your personal data with affiliates outside of the EEA on the express written authorization of our client organization (the Controller).

As an additional measure, ExpertCollege Holding (which Xpedite is part of) has implemented an EN-ISO/IEC 27001:2017-certified Information Security Management System (ISMS) to ensure the confidentiality, integrity and accessibility of your data.

6. Your rights

When we process your personal data, you are referred to as a Data Subject under the GDPR. As a Data Subject, you enjoy various rights regarding the protection of your privacy.

When Xpedite acts as a Processor of your personal data, we shall assist the Controller (our client organization) in responding to your requests regarding the processing of your personal data. Please contact the Controller to exercise your rights as a Data Subject.

When we act as a Controller of your personal data, you can contact us at any time to exercise your rights. More information about this can be found at the bottom of this page.

As a Data Subject, you have the following rights:

  • Right of access: access to personal data stored and processed by us;
  • Right to rectification: the right to have incorrect personal data or information stored by us corrected;
  • Right to erasure: the right to have personal data stored and processed by us erased;
  • Right to object: the right to object to the processing of your personal data on grounds of legitimate interest or for direct marketing.
  • Right to data portability: the right to receive your personal data in a structured manner so that you can transmit the data to another Controller.
  • Right to restriction of processing

If you wish to exercise any of the above rights, please email dpo@expertcollege.com. We may request additional information to verify your identity. We will inform you when we have processed your request and aim to respond within 4 weeks.

7. Data Protection Officer

Xpedite has appointed a Data Protection Officer (DPO) to oversee how it processes your personal data. The DPO advises Xpedite’s management and staff on all matters related to the processing of personal data and privacy.

The DPO is also your first point of contact for questions or comments about Xpedite’s processing of your personal data, or if you wish to exercise your rights under the GDPR. You can also contact our DPO if you believe Xpedite’s handling of your personal data is incorrect or unlawful. To do so, send an email to dpo@expertcollege.com, addressed to Ms M. Vasileva.

You can also contact the DPO by post at the following address:

Xpedite B.V.

Attn: Data Protection Officer
Gondel 1
1186 MJ AMSTELVEEN

8. Complaints

If you are dissatisfied with our response to your question or comment, or with the way we have processed it, and you believe we are handling your data unlawfully, you can report this to the Dutch Data Protection Authority. This organisation enforces privacy laws and regulations on behalf of the government. You can submit your report or complaint via its website: https://www.autoriteitpersoonsgegevens.nl.

Last updated: 22.05.2024