The General Data Protection Regulation (GDPR) (EU)/679 is a law that came into effect on the 25th of May 2018 as per EU regulations. It gives all citizens within the European Union and European Economic Area greater control over their personal data.
Businesses and similar corporate entities are now required to receive consent to acquire data and must be transparent about all forms of data they process and store, whether personal or anonymised. Furthermore, all citizens have the right to access data about them that has been collected by any entity, and can limit or revoke said entity’s access to it at any time. All business processes must be designed to the highest levels of security to ensure that no personal data can be leaked or exposed to external parties without consent.
Blexr is fully compliant with the regulations of the GDPR law, and as such we guarantee that we have taken all necessary actions to ensure that all persons with any form of affiliation to Blexr and the Blexr website – whether as an applicant or as a site visitor – have their privacy and data fully respected and protected.
This page provides a detailed overview of what kind of data we collect; how we process and store it; and what your GDPR rights are in relation to the personal data collected by Blexr.
Acronyms Used on This Page
GDPR – General Data Protection Regulation
An EU regulation that came into effect on the 25th of May 2018. The primary aim of the GDPR law is giving EU and EEA citizens more control and protection over the data about them that gets collected by corporate entities. You can read more about GDPR here: https://www.eugdpr.org/
DPO – Data Protection Officer
In line with GDPR compliance, all businesses are now required to employ a Data Protection Officer. People who take on this role are responsible for overseeing the protection of all personal data that is processed within the company. Data Protection Officers should be the first point of contact for users who have queries or concerns regarding their personal data.
DNT – Do Not Track
If you do not want your browsing behaviour to be tracked, then you have the right and ability to turn on a Do Not Track feature in your browser that will alert all the sites you visit of your choice.
About Blexr and The Site
To get a more comprehensive overview of the data we collect, how we process it, and why we would want to store it, it is vital that you first understand who we are, what we do, and what the role of this site is in relation to our overall operation.
Blexr is a performance marketing company established in 2015 with a focus on iGaming, Forex and Binary industries. This is our corporate website, and we use it for two main functions: advertising our services to potential clients, and advertising vacant positions within our company.
Basic Company Structure – email@example.com
DPO Information – firstname.lastname@example.org
Contact Information – email@example.com
What Data We Store
At Blexr, the data we collect is based on two categories of users: users who are simply visitors of the site, and users who apply for a job or otherwise contact us directly through the site. This section explains the different kinds of data that we receive based on user behaviour on the Blexr website.
If you are a visitor:
We collect visitor data so that we can keep track of our Population Metrics, which is a detailed documentation of how many and what kinds of users visit our site. We assure users that all data under this category is totally anonymised to us and therefore is not personal.
To achieve this we run scripts from a select number of Third-Party Vendors on our website, as this enables us to gain more detailed insights into our Population Metrics. We stress that all information accessed by such Vendors is completely anonymised and does not compromise the identity or personal data of any person visiting our site. As a user of www.blexr.com, we assume that you agree to having your anonymised data accessed by these Vendors as described below.
|Description||Google Analytics is a set of tools that collects and uses information for statistical research and for online advertising tracking and optimisation purposes.|
|Our Usage||We use Google Analytics to be able to optimise our website designs, gain insight on popular features, identify usage trends, track the delivery of our promotional content and, more generally, to know our market better in terms of geographical distribution, demography and usage patterns.|
|Legal Basis||Our legal basis for using this script within our website is a legitimate business interest.
Without using Google Analytics, we would not be able to constantly update the website to ensure that we are providing you with the best services that we can provide you with relative to the competition. All the data that is provided to us by this script is either anonymous or pseudonymous and therefore serves a function strictly in relation to research that we conduct to be able to continuously improve our services.
You may still opt-out of type of tracking by using the DNT feature on your browser or by installing; Google Analytics Opt-out browser plugin
Ad Views, Analytics, Browser Information, Cookie Data, Date/Time, Demographic Data,
Hardware/Software Type, Internet Service Provider, Page Views, Serving Domains
Search History, Location Based Data
Personally Identifiable Information
IP Address, Unique Device ID
|Data Sharing||Aggregate data, Anonymous data and PII data might be shared by Google with third parties, but not with us.
Personally Identifiable Information may also be shared with third parties.
|Data Retention||Your data is stored indefinitely|
|Contact Information||Privacy Matters
1600 Amphitheatre Parkway,
Mountain View, CA, 94043,
Twitter Button & Twitter Syndication
|Description||Twitter Button and Twitter Syndication are two social media trackers belonging to Twitter.
When You use the Twitter button (including tweet and share) or widget, Twitter will receive information about
You and a Twitter cookie will be stored on Your device.
|Our Usage||Twitter uses the information that it receives from its button and syndication trackers to customize the
marketing content that Twitter shows You, including targeted ads. Twitter also uses the data for
which include selling aggregate data to third-parties.
|Legal Basis||Our legal basis for using these scripts within Our website is Our legitimate interest.
Part of our marketing strategy entails using Pay-Per-Click marketing and the billable cost for
Analytics, Browser Information, Cookie Data, Date/Time, Demographic Data, Hardware/Software Type,
Search History, Location Based Data
Personally Identifiable Information
IP Address, Device ID, Name, Address, Phone Number, Email Address, Login, Financial Information
|Data Sharing||Aggregate, Anonymous and Personally Identifiable data is shared with third parties.
Special categories of data are also shared with third parties.
|Data Retention||Your data retention period is based on your profile setting with Twitter.
Please contact Twitter for more information.
|Contact Information||Twitter Inc.
1355 Market Street,
San Francisco, CA, 94103,
If you are applying for a job/contacting us:
We collect the necessary personal data that enable us to evaluate your credentials as an applicant with Blexr, as well as to keep in touch with you as necessary across different stages of the recruitment process. The personal data that we would have access to is your: Name, Surname, Email, LinkedIn Profile, as well as your CV and any information you choose to disclose on it. For example, if you include your home address and phone number in your CV, then we will also have access to that data. We would also have access to any comments or salary negotiations provided by the hiring manager. All of the above is restricted to authorised personnel only, as described below.
|Application||Data Type||Personal Data Processed||Who can access my data?||Retention Period||Who collects the data|
|Internal Analytics||Anonymized||N/A||Product Team||Indefinite||[[SITE_NAME]]|
|Google Analytics||Anonymized||N/A||Product Team||Indefinite||Google Analytics|
|Active Campaign||Personal Data||– Email Address
|– Email marketing manager
– Active Campaign Personnel
|Until unsubscribed||Relayed from [[SITE_NAME]] to Active Campaign through a secure tunnel|
How We Process and Store Your Data
Our staff follows and maintains strict procedures when it comes to processing and storing the data of our site users, job applicants, and any other persons otherwise in contact or affiliation with Blexr.
We stress that access to data is granted only on a need-to-know basis to the people who require it so as to carry out their business activities within Blexr. All persons with access have been trained to follow data processing procedures to the rigour that is expected of them as per GDPR regulations and any other data privacy laws.
Below is an overview of all the procedures we undertake when processing and storing personal and anonymised data in different contexts.
Data from Job Applicants
There are a number of ways through which applicants can send their personal data to Blexr for recruitment purposes, including: the Careers page portal on the Blexr site; a direct email to the company inbox; third-party recruitment agencies; and LinkedIn.
If a user emails his CV and/or LinkedIn profile directly to [[CAREERS_EMAIL]], then his personal data will be sent directly to Blexr’s inbox.
If a user applies through a third-party agent such as a recruitment agency, we trust that said user will have consented to supplying said agency with his personal data. We do require that any agency working with us is fully GDPR compliant and is able to provide proof of your consent before sending us your personal information. Failing to do so qualifies for the complete deletion of your information within 1 working day of receiving it.
If a user submits an application to Blexr through the LinkedIn portal, they must give their consent to having their LinkedIn Data downloaded freely as a template.
Unless stated explicitly otherwise, all data pertaining to recruitment is kept indefinitely unless the user specifically requests that Blexr deletes it. This enables us to re-evaluate any candidates at later stages, including for other vacancies that may become available at a later stage. You may revert your consent to this at any time by emailing our DPO on; firstname.lastname@example.org
Data Published on Social Media
Blexr makes use of the following social media channels as part of its marketing strategy: Facebook, Instagram, LinkedIn and Twitter . Often, this includes posting pictures of company activities in public or private locations.
In private locations (such as an office setting), we seek to obtain consent from all employees and non-employees who will be present in the activity. We do so by asking them to sign a consent letter. Should any person not wish to give their consent, then Blexr respects that choice and will not upload any pictures that feature them.
In public locations, our Blexr photographer/videographer will be clearly marked and will notify those in the area that all captured media may be posted on social media. Anyone not comfortable being seen on social media should stay clear of the photographer/videographer.
Data from Cookies
This technology allows us to extract and store the analysable information needed for our Population Metrics, but restricts us from learning or collecting any personal data about our site visitors. We maintain that having cookies enabled on our site allows us to better our user experience due to having analysable metrics. However, should you not wish for us to track your activity to any degree, you can enable DNT on your browser. To learn about how you can enable this feature, refer to the information below:
Firefox – https://support.mozilla.org/en-US/kb/how-do-i-turn-do-not-track-feature
Chrome – https://support.google.com/chrome/answer/2790761?co=GENIE.Platform%3DDesktop&hl=en
Internet Explorer – https://support.microsoft.com/en-us/help/17288/windows-internet-explorer-11-use-do-not-track
Microsoft Edge – https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
Safari – http://osxdaily.com/2012/08/21/how-to-enable-do-not-track-in-safari-6/
How We Prevent Data Leaks
At Blexr, we exercise full diligence when it comes to data storage and security. We employ several measures to ensure that the data we collect cannot be accessed by unwanted parties, whether internal or external.
First and foremost, the personal data we receive from job applicants is solely handled and shared between the HR team, Hiring Managers and their respective managers. The below table explains how we subdivide personal information for internal use; who is allowed to access specific subdivisions of personal information; and the retention period for each subdivision.
Access to the website server and its databases is limited to the IT department, which means that the same dedication of security is applied when it comes to the visitor data we receive. Though the Population Metrics created from this data may be shared internally with a select few people for the sake of analysis, no individual user’s identity can be compromised as the Metrics are built from anonymised data.
All data that we collect, whether personal or anonymised, is backed-up, and all backups are fully encrypted and password-protected to ensure that they cannot be accessed by unwanted parties.
The Blexr website runs via Secure Sockets Layer (SSL), which is the standard security technology in retaining user privacy. SSL operates by creating an encrypted link that is established between a web server and a browser when a user logs on to any site that supports this technology. This link is responsible for maintaining the privacy of users’ data throughout their online interactions.
To maintain the Blexr website at the standard of security expected of us, we perform regular security audits that enable to identify and rectify any issues that may surface as early on as we can. Though our implemented measures minimise the risk of such issues greatly, Blexr believes in the importance of constant security assurance.
How We Proceed Should a Data Leak Occur
We reiterate that at Blexr, we have taken all possible measures within our operational limits to ensure that no data leaks or breaches occur across our operations. However, we acknowledge that we are not infallible and that in extremely rare and unfortunate occasions such a leak may occur, whether due to human error or circumstances beyond our control.
We fully respect that our users have a right to be informed in such situations, and accordingly are fully transparent with them. Should a data leak occur, we attempt to identify all the affected users. If we are able to do so, those users will be notified by email within 24 hours of the breach / leak. If we cannot determine the extent of the breach / leak, all users will be notified by email within 48 hours.
Your Rights and Our Obligations
As part of the aim of GDPR aim to give EU and EEA citizens more control over their data, you have certain rights that all companies that have obtained your data must adhere to. You have the right to access such information stored on its database, and can opt to limit or revoke access to it at any time.
Blexr fully recognises the importance of respecting the GDPR rights of every individual who comes across the www.blexr.com website and Blexr’s social media presence. As a company, we are legally bound to safeguard your rights, whether you happen to be a job applicant, site visitor or social media follower. We have taken all necessary actions to ensure your rights are respected and will continue to do everything in our capacity to honour our legal obligation towards you in the most transparent manner.
You may exercise the following rights at any point during which your personal data is being collected, processed, or stored:
Right to stop data processing
If we receive a request from you asking us to stop processing any personal data which may have been obtained through your consent, we will anonymise all related information. Additionally, we will notify all our third-party vendors in possession of any data concerning you to also fulfil your request.
Right of access
You may ask us to confirm whether we are in possession of any data about you, or to view all the personal data stored. Once either or both of these requests are submitted, you will receive an email from us containing any information we have collected about you. To do so, we may require you to verify your identity first, in which case you will be contacted directly by our DPO.
Right of rectification
If you would like us to make any changes to the information stored about you, you may request this by getting in touch, and we will fulfil your request within 28 days of your notification. Wherever necessary, we will also pass on this communication to third-party vendors and partners. This is done to ensure consistency and integrity of your records across all our affiliate websites.
Right to be forgotten
You may request to have your identity forgotten by Blexr. In this case, we will proceed to anonymise all your personal information within 28 days of your notification. We will also pass your request along to all relevant third-party vendors.
Right to restriction of processing
At Blexr, we already operate in such a way as to impose certain restrictions on personal data processing. This is achieved by minimising all processing to a bare operational minimum. If, for any reason, you should feel that additional restrictions are required, we will immediately address your request and any of your concerns by imposing all the restrictions within our control within 28 days of your notification.
Right to object to automated processing, including profiling
If you object to the profiling of your data collected through our site, or do not wish to receive any automated communication from Blexr, simply notify us with a request. We respect your right to privacy and will refrain from contacting you in future, in accordance with your request.
Right of portability
Exercising your right of portability means being entitled to having your data moved around. On your request, we will move any of your existent personal data to a third-party location according to your instructions.
Right to complain about how your personal data is being processed
You have every right to remark on any issues you might have with the way we are handling your personal data. If you wish to submit a complaint about our data processing service, feel free to get in touch with our DPO on email@example.com, who will be available to address any of your queries and/or requests.
If you have any general questions about the Blexr site or want to know more about us, get in touch via firstname.lastname@example.org. To find out more about a particular vacancy, or if you’re keen to find out what it takes to join Blexr’s forces, drop us an email at email@example.com. For any data-related queries or to verify that we’re doing our utmost to protect your privacy, our dedicated DPO has all the answers at firstname.lastname@example.org.