1.2 The platform is not intended for children and we do not knowingly collect data relating to children.
1.3 This Policy may be amended by us at any time, consistent with the requirements of applicable laws and regulations. Any revisions will take effect from the date on which the amended Policy is published. This version was last updated on 28/02/2021.
1.4 vGroup International Ltd is the controller and is responsible for this platform (referred to as “we”, “us” or “our” in this Policy). vGroup International Ltd is part of vGi Holdings Ltd (collectively referred to as “vGroup” in this Policy).
2 Contacting us
2.1 If you have any questions about this Policy or our privacy practices, please contact firstname.lastname@example.org.
2.2 You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3 The data we collect about you
3.1 Personal data 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).
3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
3.2.1 Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and photograph.
3.2.2 Contact Data includes billing address, delivery address, email address and telephone numbers.
3.2.3 Financial Data includes bank account and payment card details.
3.2.4 Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
3.2.5 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 platform.
3.2.6 Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
3.2.7 Usage Data includes information about how you use our platform, products and services, which may include records of telephone conversations.
3.2.8 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3.3 We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific platform feature.
4 How is your personal data collected?
4.1 We collect this information through:
4.1.1 Direct interactions. You may give us your personal information by filling in forms or by corresponding with us by post, phone, email or otherwise.
4.1.3 Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, including analytics service providers such as Google.
4.1.4 Providers of technical, payment and delivery services.
5 Purposes for which we will use your personal data
5.1 We have set out below, a description of the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
5.2 Note that we may process your personal data for more than one lawful ground 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.
Lawful basis for processing including basis of legitimate interest
|To register you as a new customer||Performance of a contract with you|
|To process and deliver your order including: |
|(a) Performance of a contract with you |
(b) Necessary for our legitimate interests (to run our business)
|To process and respond to any requests or enquiries submitted by you||(a) Necessary for our legitimate interests (to run our business) |
(b) To take steps to enter into a contract with you.
|To manage our relationship with you which will include: |
(b) Asking you to leave a review or take a survey
|(a) Performance of a contract with you |
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud etc.) |
(b) Necessary to comply with a legal obligation
|To deliver relevant platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our platform, products/services, marketing, customer relationships and experiences||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our platform updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To carry out background checks for anti- corruption, bribery or money laundering compliance, or financial sanctions screening.||Necessary to comply with a legal obligation|
5.3 Where we need to collect your personal data for the purposes set out above, if you fail to provide that data we may not be able to provide our services to you.
5.4 We will only carry out background checks when permitted or required to comply with its legal obligations or where the client’s explicit consent has been obtained for the processing of such data, where such consent may be required by local law.
6.1 Promotional offers from us. We may use your Identity, Contact, Technical, Usage and Profile 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 products, services and offers may be relevant for you (we call this marketing).
6.2 Marketing communications. You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.
6.3 Third-party marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
6.4 Opting out. You can ask us or third parties to stop sending you marketing messages at any time [by logging into the platform and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.
8 Third-party links
9 Disclosures of your personal data
9.1 We may disclose and/or transfer Client personal data within vGroup or to third parties only for the business-related purposes set out above.
9.2 The parties to whom we may disclose or otherwise transfer your personal data include:
9.2.1 vGroup and its affiliates for purposes consistent with their legitimate business practices and this Policy;
9.2.2 vGroup employees and business associates;
9.2.3 professional advisers, including legal and other professional advisers, consultants and experts, financial organisations and advisers, insurers and third party processors utilised for risk management, compliance, legal and audit functions;
9.2.4 service providers supplying IT and system administration services and other technical IT services, such as Mailchimp;
9.2.5 persons making an enquiry or complaint, where required by law and/or with consent;
9.2.6 to an investigative body in the case of a breach of an agreement or a contravention of law;
9.2.7 as otherwise necessary or required or permitted by law or due to a request from a competent court, regulator or other authority; and
9.2.8 any prospective third party to whom we may choose to sell, transfer or merge parts of our business or our assets.
9.3 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.
10 International transfers
10.1 Given the international nature of our operations, personal data collected in the United Kingdom (“UK”) or European Economic Area (“EEA)” may be transferred to countries outside the UK or EEA, or to ‘Third Countries’ which may not have laws offering the same level of protection for personal data as those inside the UK or EEA.
10.2 We will take steps to prevent the transfer of personal data without adequate safeguards being put in place and will ensure that personal data collected in the UK or EEA and transferred internationally is afforded the same level of protection as it would be inside the UK or EEA. These safeguards may include the use of specific contracts or contractual provisions approved for use in the UK or EEA which give personal data the same protection it has in the UK or EEA, or that the country to which we transfer your personal data has been deemed to provide an adequate level of protection for personal data
10.3 Please contact us if you want further information on the adequate safeguards adopted by us for the international transfer of personal data.
11 Data Security
11.1 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.
11.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
12 Appointing data processors
12.1 When appointing third parties to carry out processing of personal data on our behalf, we shall impose contractual obligations dealing with the protection and security of that information such that these third parties are contractually required to, amongst other obligations, act in a manner consistent with our instructions when processing personal data and that they have in place appropriate technical and organisational security measures to safeguard such personal data.
13 Data retention
13.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
13.2 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, regulatory, tax, accounting or other requirements.
13.3 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
13.4 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. We may retain your contact details for these purposes.
14 Your legal rights
14.1 We will respond to requests made by you to exercise your legal rights in relation to personal data that we hold about you. Subject to applicable exemptions, you have the following rights under data protection laws in relation to your personal data:
14.1.1 Request access to your personal data. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
14.1.2 Request correction of your personal data. This enables you to have any incomplete or inaccurate information we hold about you corrected.
14.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
14.1.4 Object to processing of your personal data. This right applies where we are relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
14.1.5 Request restriction of processing your personal data. This enables you to ask us to suspend the processing of personal information about you.
14.1.6 Request transfer of your personal data to another party (known as the “right to data portability”.
14.1.7 Right to withdraw consent. In any circumstances where we have relied on your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. This will not affect the lawfulness of any processing carried out before you withdrew your consent.
14.2 If you wish to exercise any of the rights set out above, please contact us at email@example.com.
14.3 You will not have to pay a fee to access your personal data (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 could refuse to comply with your request in these circumstances.
14.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
14.5 We try to respond to all legitimate requests within one month. Occasionally it could 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.
15 Breach of this Policy
15.1 Any actual or suspected breach of this Policy should be immediately notified to firstname.lastname@example.org.