Visible Pathway Limited, a UK Registered Company Number 10816413, (“VP”, “we”, “our”or “us”) is committed to protecting and respecting your privacy. Please read the following policy to understand how we may collect information from you, what we may do with that information and what choices you can make about the way in which your information is treated. Visible Pathway Limited of International House, 24 Holborn Viaduct London EC1A 2BN United Kingdom, is a software business developing commercial and business applications that are licensed to other businesses.
VP and personal information: We are committed to lawful, fair and transparent processing of all personal information about our employees, customers, suppliers and other third parties during the course of our business activities. We will always comply with any applicable data protection legislation and we will ensure that collection and use of personal information is carried out in accordance with applicable data protection laws. As of 25 May 2018, the main law governing data protection is the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) known as the “GDPR”.
Controlling and processing information: We are the controller of all personal information used in our business for our own commercial purposes. Sometimes though, we will process personal information on behalf of another data controller and when this is the case, we will do so only in accordance with the instructions of that data controller and otherwise in accordance with the law. If we are processing on behalf of another data controller, that data controller will provide relevant information to you about how your data is being shared.
Why you should read this policy: It is important that you read this policy, together with any other documents referred to in it, so that you are aware of how any personal information relating to you will be dealt with by us.
DATA PROTECTION PRINCIPLES
We are accountable for demonstrating compliance with the GDPR’s six principles of processing personal information. These provide that personal information we deal with must be:
- processed fairly, lawfully and in a transparent manner;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
- adequate, relevant and limited to what is necessary;
- accurate and, where necessary, kept up to date;
- not kept for longer than necessary; and
- processed securely, maintaining integrity and confidentiality.
SOME BASIC DEFINITIONS WE USE IN THIS POLICY
Personal information: In this policy, when we use the term “personal information” we mean any information relating to an identified or identifiable human being. (An “identifiable natural person” is one who can be identified, directly or indirectly, for example, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, biometric, mental, economic, cultural or social identity of that person).
Sensitive personal information: In this policy, when we use the term “sensitive personal information” we mean special categories of information which are personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying someone, data concerning health or data concerning a someone’s sex life or sexual orientation.
THE KIND OF PERSONAL INFORMATION WE HOLD ABOUT YOU
You are not required to provide any personally identifiable information on the public areas of this website. However, you may choose to do so by completing forms on various sections of our website or by otherwise requesting information from us or subscribing for our services.
We may also collect information from you as a result of your relationship with one or more of our customers or other service providers.
We may collect, record, organise, structure, store, adapt, alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, erase or destroy the following types of personal information about you
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Job title and place of work
- Demographic information such as your postcode
- Information relevant to customer surveys
- Date of birth
- Information about your use of our information and communications systems, including any log in details for your account and any service messages between us regarding any problems with our site
- Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access
We may also automatically collect certain non-personally identifiable information when you visit our website- for further details please see our Cookies section.
By using any of our services, including our website, and by providing us with any personal information you are indicating that you consent to the use of your personal information as set out in this policy.
HOW WE WILL USE PERSONAL INFORMATION
We will only use personal information when the law allows us to do so and relying on a relevant basis for lawful processing in each instance. We will use your personal information in the following circumstances, relying on the basis of processing indicated.
Basis of processing: Where it is necessary for our legitimate interests and we have undertaken an assessment to determine that processing for those interests (listed below) does not outweigh your interests and fundamental rights, considering the nature and impact of the processing and any relevant safeguards we can put in place.
- To improve the design and content of our website
- To manage and maintain our relationship with you
- To provide you with further information about our products and services
- To audit usage of our website
- To ensure that content from our site is presented in the most effective manner for you and for your device (online identifiers, location data and other technical information).
- To provide you with information, products or services that we feel may interest you, (where you have consented to be contacted for such purposes to the extent consent is required by law) (contact details and any information relating to personalisation preferences or relationship status).
- To allow you to participate in interactive features of our service, when you choose to do so (online identifiers, location data and other technical information).
- To notify you about changes to our service (contact details).
- To maintain a basic amount of information about you and your activity history, in order to provide you with a service tailored to your preferences (contact details, any payment history and information relating to personalisation status).
Basis of processing: Where we need to comply with a legal or regulatory obligation.
- To retain basic transaction details for the purpose of tax reporting (contact details and transaction history).
Basis of processing: Where you have consented to the processing.
- To send you direct marketing communications via email, text message, post or telephone call (contact details). You have the right to withdraw consent to any such use at any time by contacting us.
As indicated above, we may use your personal information to provide you with information about services which may be of interest to you and we may contact you about these by post, email or telephone. This is known as direct marketing.
Examples of direct marketing may include:
- sending promotional emails about new products, special offers, customer events or other information which we think you may find useful or interesting using the email address which you have provided;
- contact youfor market research purposes (by email, phone or mail).
We will only process personal information for the above purposes with your specific consent. You have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below.
We have put in place internal procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
All communications to our servers happen using secure socket layer technology (or “SSL”) – VP follows accepted industry standards to protect personal information during transmission and storage. Unfortunately, no method of transmission over the Internet or electronic storage is 100% secure and, while VP strives to use commercially acceptable standards to protect personal information, VP cannot guarantee absolute security.
We will not keep personal information in a form which permits identification of individuals for longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required (or, where we are processing on behalf of another data controller, return their information to them). We shall keep data on our prospect database for not longer than 3 years from receipt subject to an individual’s right to unsubscribe or be forgotten at any time.
We will only keep personal information for as long as is necessary for the purpose or purposes for which that personal information is processed; and we will let anyone about whom we process data know how long that is or the criteria that go into deciding how long that is.
Our site may, from time to time, contains links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or the security of these websites. Please check the relevant policy before you submit any personal information to these websites.
Under certain circumstances, you have rights under data protection laws in relation to your personal information, as summarised below.
You have the right to:
- Request access to your personal information(commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal information.This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal information where we are relying on a legitimate interest(of our own or of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at email@example.com. We aim to respond to all legitimate requests within one month (and if we are only processing the data in question on behalf of another party, the response may actually come from that other party as the relevant data controller). Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests; in this case, we will notify you and keep you updated.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive – alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
Strictly necessary cookies
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
All data or information which is collected by the setting of a cookie is anonymous, and cannot identify you or your use of the website personally. You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
||This cookie is set by our analytics provider, Google Analytics and is used to collect data and information to better understand how the website is used. Any data or information which is collected is anonymous.
||This cookie is set by our marketing automation provider, HubSpot and is used to collect data and information to better understand how the website is used. Any data or information which is collected is anonymous.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
DATA PROTECTION OFFICER
The Data Protection Officer (“DPO”) is responsible for ensuring compliance with GDPR and with this policy. Please contact the DPO at firstname.lastname@example.org. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the DPO.
CHANGES TO THIS POLICY
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.