WHAT IS THE PURPOSE OF THIS POLICY?
VodaCompliance Ltd, of Voda House, 21 Hobart Quay, North Harbour, Eastbourne, East Sussex BN23 5PB, is a limited liability company registered at Companies House with registration number 11345025.
VodaCompliance Ltd is committed to protecting the privacy and security of your personal information.
This policy also aims to inform you about your privacy rights and how the General Data Protection Regulation (GDPR) protects you.
This website is not intended for children.
1. Data Controller
4. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data purchases of our products or services made by you, your interest preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Depending on the nature of the work that we are undertaking for you, we may in certain cases need to collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We may in certain cases also need to collect information about criminal convictions and offences.
5. If You Fail To Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel the contract, which you have with us, but we will notify you if this is the case.
6. How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for or request our products or services;
- subscribe to receive any of our newsletters or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from publicly available sources such as Companies House.
7. Our Lawful Basis For Collecting This Data
The law on data protection sets out a number of lawful bases for the collection and processing of personal data. The lawful bases that we rely upon include:-
In some instances, we may collect and process your data with your consent e.g. in relation to certain marketing activities.
We may collect and process your personal data in the interest of conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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).
Performance of Contract
We may collect and process your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract because you wish to instruct us to carry our services for you and/or you wish to purchase products from us.
8. Purposes For Which We Will Use Your Personal Data
We have set out below, in a table format, a description of the purposes for us collecting and processing your personal data, and we explain the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful reason depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose for collecting the data
||Type of data being collected
||Lawful basis for processing the data
|To register you as a client
||Identity and contact details
||This data is necessary for performance of a contract with you.
|To process and deliver our products and services to you in accordance with our terms and conditions of business and to administer, support, improve and develop our business generally and enforce our legal rights, including to:
- obtain, record and securely keep details of your instructions and our communications with you through our computer, telephonic and electronic systems or meetings in person;
- manage payments, fees and charges; and
- collect and recover money owed to us
|Identity, contact, financial, transaction, technical, profile and usage details
||This data is necessary for performance of a contract with you, for our legitimate interests.
|To manage our relationship with you which will include:
- Asking you to leave a review or take a survey
|Identity, contact, profile, marketing and communications
||This data is necessary for performance of a contract with you, for us to comply with a legal obligation and for our legitimate interests
|To enable you to provide feedback, complete a survey or you providing us with your business card / contact details
||Identity, contact, profile, usage, marketing and communications
||This data is necessary for performance of a contract with you and for our legitimate interests
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), monitoring use of our information and communication systems and network and information security, including preventing unauthorised access to our computer, telephonic and electronic communications systems and preventing malicious software distribution.
||Identity, contact, technical and usage
||This data is necessary for our legitimate interests and for us to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
||Identity, contact, profile, usage, marketing and communications and technical details
||This data is necessary for our legitimate interests
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
||Technical and usage details
||This data is necessary for our legitimate interests; we also may have your consent
|To make suggestions and recommendations to you about products or services that may be of interest to you
||Identity, contact, financial, transaction, technical, profile and usage
||This data is necessary for our legitimate interests
We have a legitimate interest to use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which of our products and services may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details and, in each case, you have not opted out of receiving marketing from us.
We would like to keep you in touch with our business now and in the future to give you the opportunity to benefit from legal updates, and products and services that may be of interest to you. However, it is important to us that the content we share is relevant to our audience and we strive to provide you with choices regarding certain personal data uses, particularly around marketing.
You may contact us at any time to confirm or amend your preference details to ensure that you continue to receive the information that you’d like in the way you want to receive it.
We will never sell your information to third parties.
10. Opting Out
You can ask us to stop sending you marketing messages at any time or by contacting us and advising us of your marketing preferences or by following the opt-out links on any of our marketing messages sent to you.
12. Change Of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at any time.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
13. Disclosures Of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
External Third Parties such as
- service providers acting as processors based in the EEA who provide IT and system administration services.
- HM Revenue & Customs, regulators and other authorities or fraud prevention agencies acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Professional advisers acting as processors or joint controllers including lawyers, brokers, agents, bankers, auditors and insurers based in the EEA or such other jurisdictions considered to have adequate data protection legislation that is equivalent to the GDPR and who provide consultancy, broking etc., banking, legal, insurance and accounting services.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
14. International Transfers
We do not transfer your personal data outside the European Economic Area (EEA). If for any reason it does become necessary to do so we shall either seek your specific consent or advise you of any other legal basis for processing.
If we ever need to transfer your personal data out of the EEA, we shall take steps to ensure a similar degree of protection is afforded to it by ensuring safeguards are implemented.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
15. Third Party Data Processors We May Use To Help Process Your Data
We may use the following third party data processors to store or process your personal data:
- Google Analytics
- DoubleClick for Publishers (Google)
- Sprout Social
- Survey Monkey
- Heart Internet
We are committed to ensuring that all of the above third party data processors that process personal data on our behalf are fully compliant with the GDPR.
We do not enter into contracts with other data processors unless they can demonstrate the steps they have taken towards compliance.
16. 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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and the relevant regulator of a breach where we are legally required to do so.
17. How Long Will You Use My Personal Data For?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
You can request from us details of retention periods for different aspects of your personal data.
We feel that six years is a legitimate time to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for tax purposes.
18. Your Legal Rights
You are entitled to:
- Request details of the data we hold on you;
- Request that we rectify the data we hold on you if you believe it to be incorrect;
- Request that the data we hold on you be erased;
- Request that we restrict the processing of the data we hold on you;
- Obtain and reuse the data we hold on you for different services;
- Object to the use of your data for direct marketing.
To exercise your rights and request any of the above, please email firstname.lastname@example.org, or write to us at VodaCompliance Ltd, Voda House, 21 Hobart Quay, North Harbour, Eastbourne, East Sussex BN23 5PB.
We will not charge you to request any of the above, unless the request is deemed to be excessive. In the unlikely event of this happening, we may charge you a small fee to cover the costs of this excessive request.
25 May 2018