VIADEX LIMITED – PRIVACY NOTICE
Last modified: 08.11.2023
1. IMPORTANT NOTICE
1.1. This is the Privacy Notice of Viadex Limited (company number 04066603) whose registered office is at Unit 20 Red Lion Road Business Park, Red Lion Road, Surbiton, Surrey, KT6 7QD (“we”, “us” or “our”) and sets out how we collect and process your personal data. This Privacy Notice also provides certain information that is legally required and lists your rights in relation to your personal data.
1.2. We take our data protection responsibilities very seriously and we comply with all applicable Data Protection Legislation in force from time to time. For the purposes of this Privacy Notice, “Data Protection Legislation” means the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 (“DPA”), the Protection of Personal Information Act (“POPIA”) and any other data protection legislation that may apply to our processing of personal data.
1.3. This Privacy Notice relates to personal information that identifies you. We refer to this information throughout this Privacy Notice as “personal data” and section 2 sets out further detail of what this includes.
1.4. Please read this Privacy Notice to understand how we may use your personal data.
1.5. This Privacy Notice may vary from time to time so please check it regularly.
2. THE PERSONAL DATA WE COLLECT ON YOU
2.1. We may collect the following personal data about you:
2.1.1. personal data you provide to us in person, via our website or by telephone, including the personal and contact details you supply when establishing a profile on our website or requesting that we contact you in relation to a query. For example:
2.1.1.1. your first and last name;
2.1.1.2. demographic data such as your gender, title, country and preferred language; and
2.1.1.3. log-in and account information for authentication purposes and account access.
2.1.2. personal data in the form of images or video footage that is taken at one of our locations;
2.1.3. personal data gathered using cookies, including;
2.1.3.1. details of your visits to our website including but not limited to traffic data, location data, weblogs and other communication data;
2.1.3.2. information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual;
2.1.4. personal data you provide when:
2.1.4.1. you purchase our solutions and/or services, or we process orders and payment transactions;
2.1.4.2. you provide feedback about our solutions and/or services;
2.1.4.3. you register for our events, workshops or seminars;
2.1.4.4. we conduct our administrative and business functions;
2.1.4.5. you enter into a competition or promotion;
2.1.4.6. when you request our marketing material or email newsletter; and
2.1.4.7. you submit a query to us or which is collected via social media, or when there are communications between you and our representatives.
2.1.5. For more details on the specific cookies we use on our site, please visit our cookie notice.
2.2. We may also create Personal Data about you, for example, if you contact us by telephone to make a complaint or ask a question, then we may make a written record of key details of the conversation so that we can take steps to address the complaint or the question.
2.3. We may also obtain your personal data from an external lead generation platform, which may include your name, job title and company. This information is obtained using IP lookup, a publicly accessible source.
KEY INFORMATION ABOUT YOUR PERSONAL DATA
2.4. Data controller and contact details
2.4.1. For the purposes of the Data Protection Legislation, we are the controller of the personal data described above and as a controller we use (or ‘process’) the personal data we hold on you in accordance with this Privacy Notice.
2.4.2. If you need to contact us in connection with our processing of your personal data, then you can do so at dpo@viadex.com.
2.5. Legal grounds for processing
2.5.1. We collect and process your personal data for a variety of different purposes which are set out in further detail below.
2.5.2. In some cases, we will ask for your consent to process your personal data. However, in certain circumstances the Data Protection Legislation allows us to process your personal data without needing to obtain your consent. For example, this may be because it is necessary in order for us to peruse a legitimate interest we (or another party) may have or where it is required for us to comply with a legal obligation we are subject to.
3. HOW WE USE YOUR PERSONAL DATA & OUR BASIS FOR USING IT
3.1. We may process your personal data for the following purposes and on the following lawful bases:
| How we use your personal data | The legal basis on which we can do this (this is what the law allows) | |
| In order to perform our contractual obligations to you. This would include our fulfilling orders you have placed for goods or services, contacting you in relation to any issues with yourorder or where we need to provide your personal data to ourservice providers (e.g. the company which processes our payments). |
The processing is necessary for the performance of a contract which you have entered into, or where you request us to process your data prior to entering into a contract |
|
| In order to comply with our own legal obligations, e.g. healthand safety legislation, or to assist in an investigation (e.g. from the police). | The processing is necessary for compliance with a legal obligation to which we are subject | |
| In order to use your personal data in life or death situations and there is no time to gain your consent (e.g. in the event ofan accident and we have to give your personal details to medical personnel). | The processing is necessary in order to protect your vital interests or the vital interests of another individual | |
| In order to use your personal data to operate our business, but otherwise than in performing our contractual obligations to you. These would be our ‘legitimate interests’ for the purposes of Data Protection Legislation and are as follows: | Where processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interestsor fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child | |
| ● | to send you important notices such as communicationsabout changes to our terms and conditions and policies; | |
| ● | to deal with any misuse of our website; | |
| ● | to provide you with important real-time information aboutproducts or services you have ordered from us (e.g. achange of time or location due to unforeseen circumstances); | |
| ● | to send you information you have requested; | |
| ● | to deal with your enquiries; | |
| ● | where you have submitted a job application we may for a reasonable period keep your details on file for futurereference should a suitable position subsequently become available and we may send you information about job opportunities; | |
| ● | to develop, deliver and improve our goods or services; | |
| ● | to help us develop our website to be more useful to you; | |
| ● | for internal purposes for research, analysis, testing,monitoring, customer communication, risk managementand administrative purposes; | |
| ● | to protect and defend our rights or property; | |
| ● | to notify winners of online competitions; | |
| ● | to send you surveys in connection with our solutionsand/or services; | |
| ● | to assist in the investigation of suspected illegal orwrongful activity. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; | |
| ● | to sell, make ready for sale or dispose of our business inwhole or in part including to any potential buyer or their advisers; or | |
| ● | in order to enforce or apply our website terms of use, terms and conditions of supply and other agreements with third parties. | |
In addition, we may obtain certain special categories of your data (“Special Categories of Data”), and this Privacy Notice specifically sets out how we may process these types of personal data. The Special Categories of Data are: (i) personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; and (ii) the processing of genetic data, biometric data for the purposes of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Where we do so we will seek your explicit consent before processing this data.
The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way.
You may at any time withdraw the specific consent you give to our processing your personal data. Please contact us using the contact email address dpo@viadex.com to withdraw your consent.
Please note even if you withdraw consent for us to use your personal data for a particular purpose we may continue to rely on other bases to process your personal data for other purposes.
3.2. Who receives the personal data you provide to us
3.3. We may share your personal data with the following recipients:
3.3.1. our PR agency and customer feedback;
3.3.2. HMRC, legal and other regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;
3.3.3. external professional advisers such as accountants, bankers, insurers, auditors and lawyers;
3.3.4. law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;
3.3.5. third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
3.3.6. third parties which are considering or have decided to acquire some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution or liquidation);
3.3.7. third parties operating plugins or content (such as Facebook, Google, LinkedIn, Twitter, Instagram, CommuniGator) on our website which you choose to interact with;
3.3.8. our digital marketing service providers including;
3.3.8.1. Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.
3.3.9. In addition, we may disclose the personal data you provide to us to our group companies and affiliates or other third- party data processers who process data on our behalf. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Notice.
3.4. Transfers of your personal data to other countries
Your personal data may be transferred to other countries when it is shared with our group entities. It is also possible that personal data we collect from you may be transferred, stored and/or processed outside the UK by our data processors. This is because the organisations we use to provide our services to you are located in other countries.
We have taken appropriate steps to ensure that where personal data processed outside the UK, it has an essentially equivalent level of protection as it has within the UK. We do this by ensuring that:
3.4.1. Your personal data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation) This includes the use of approved frameworks for the sharing of personal data, such as the UK Extension to the EU-US Data Privacy Framework; or
3.4.2. We enter into either International Data Transfers Agreements (IDTAs) or Standard Contractual Clauses (SCCs) (with the UK Addendum) with the receiving organisations and ensure that supplementary measures are also applied, where necessary.
3.5. How long we will hold your personal data for
3.5.1. We will retain your personal data for as long as is necessary for us to carry out the purposes outlined above and for a reasonable period thereafter to enable us to meet our contractual and legal obligations and to deal with complaints and claims. We keep the length of time that we hold your personal data for under continual review. These reviews take place on a 6 month basis.
3.6.2. At the end of the retention period, your personal data will be securely deleted or anonymised, for example by aggregation with other data, so that it can be used in a non-identifiable way for statistical analysis and business planning.
3.7. Security of your personal data
3.7.1. We have implemented appropriate technical and organisational measures to safeguard your personal data and protect it from accidental or unlawful destruction, loss or alteration and from unauthorised disclosure or access.
3.7.2. In addition to the technical and organisational measures we have put in place, there are a number of simple things you can do to in order to further protect your personal information, such as;
3.7.2.1. Never share a One Time Passcode (OTP).
3.7.2.2. Never enter your details after clicking on a link in an email or text message.
3.7.2.3. Always send confidential information by encrypted email where possible this reduces the risk of interception.
3.7.2.4. If you’re logged into any online service do not leave your computer unattended.
3.7.2.5. Close down your internet browser once you’ve logged off.
3.7.2.6. Never download software or let anyone log on to your computer or devices remotely, during or after a cold call.
3.7.2.7. Secure Online Services
3.7.3 You can easily identify secure websites by looking at the address in the top of your browser which will begin https:// rather than http://.
3.8. Why should you provide us with personal data?
Providing your personal data to us may be a requirement of entering into your contract with us for the provision of goods and services. Your personal data belongs to you and it is your choice as to whether you provide us with your personal data. However, because we may require your personal data in order to perform our contractual obligations to you, please be aware that if you do not provide all of the personal data we request from you then we may not be able to perform to the level you expect under our contract with you. An example of this would be where we are unable to provide you with certain products or services as we do not have your full details, or where we cannot perform our contract with you at all because we rely on the personal data you provide in order to do so. Please see our terms and conditions for further details.
4. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
Subject to applicable law including relevant data protection laws, in addition to your ability to withdraw any consent you have given to our processing your personal data (see paragraph 3.1), you may have a number of rights in connection with the processing of your personal data, including:
4.1. the right to request access to your personal data that we process or control;
4.2. the right to request rectification of any inaccuracies in your personal data or, taking into account the purposes of our processing, to request that incomplete data is completed;
4.3. the right to request, on legitimate grounds as specified in law:
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- a) erasure of your personal data that we process or control; or
- b) restriction of processing of your personal data that we process or control;
4.4. the right to object, on legitimate grounds as specified in law, to the processing of your personal data;
4.5. the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller, to the extent applicable in law; and
4.6. the right to lodge complaints regarding the processing of your personal data with the Information Commissioner’s Office or other relevant supervisory body. Please see https://ico.org.uk/concerns/ for how to do this.
If you would like to exercise any of the rights set out above, please contact us using the contact details set out in paragraph 2.4.
5. LINKS TO OTHER WEBSITES
5.1. This policy only applies to Viadex Limited. If you link to another website from our website, you should remember to read and understand that website’s privacy policy as well. We are not responsible for any use of your personal data that is made by unconnected third party websites.
