VIRTUOSO PARTNERS Limited ("We", “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the General Data Protection Regulation (“GDPR") the Data Controller is VIRTUOSO PARTNERS Limited, also known as VIRTUOSO PARTNERS or VIRTUOSO PARTNERS Ltd.
YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all of the following types of information from you in the course of your use of the website or during the provision our services:
Information that you provide by filling in forms on our website. This includes the information you have provided or that We may collect from you at the time of registering to use the website, subscribing to our service, or requesting further information or services. We may also ask you for information when you report a problem with the website.
Specifically, personal details such as name, username, email address, phone number and place of work, social media usernames when using the Website, completing our survey forms or, using our services.
In respect of the personnel engaged by our suppliers and resellers (or prospective suppliers and resellers), and with whom we come into contact in connection with the relationship between Us and our reseller and supplier, we will process your contact details such as your name, e-mail address, phone number, place of work and any other information that you provide to us.
If you contact Us, We may keep a record of that correspondence.
We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.
Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
When using our online “Contact” form your name, e-mail address and enquiry details are required from you to enable Us to respond to your enquiry. When using our online “Registration” form your username, name, e-mail address, and password are required from you to enable Us to register you as a member. Your email address, name and place of work is required from you to enable Us to add you to our Newsletter mailing list. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.
Information We Collect from Other Sources
We may also obtain personal data from other sources as follows:
publicly available information or information received as part of our membership to various organisations which our resellers or prospective resellers are also a member, various trade organisations and preferred partner status with suppliers.
your name, organisation, job title and other information that you make public on social media, such as LinkedIn.
USES MADE OF YOUR INFORMATION
We use information held about you in accordance with the following “legal bases” and for the following purposes:
If you are engaged by one of our customers, resellers or suppliers, we may process your data in order to perform our obligations pursuant to a contract with that customer or reseller or supplier. Where we do so we rely on “legitimate interest” and the legitimate interest is “carrying out a contract with a customer, reseller or supplier”.
To provide you with our newsletters. We rely on “consent” as the legal basis for this processing.
We rely on your consent as the lawful basis where you have agreed to participate in a survey, and for the processing of such personal information as has been collected through that survey.
To respond to your enquiries. Where you have contacted us via our online “Contact” form, e-mail and telephone or participated in any surveys, we rely on “legitimate interest” and the legitimate interest is “responding and contacting you regarding the enquiries you have made in relation to the services we offer”.
To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website. We rely on “legitimate interest” as the legal basis for this processing, and the legitimate interest is the maintenance and improvement of our Website for the benefit of all our users.
To notify you about changes to our service. We rely on “legitimate interest” and the legitimate interest is “carrying out a contract with a customer, reseller or supplier”.
To allow you to participate in interactive features of our service, when you choose to do so.
We may use information held about you to promote our products and services that may be of interest to you. We will only do this where we reasonably believe that our services may be of interest to you and we rely on “legitimate interest” to promote our products and services to you.
If you do not want us to use your data in this way please either (i) tick the relevant box situated on the form on which we collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform Us at any time by contacting us at the contact details set out below.
DISCLOSURE OF YOUR INFORMATION
We only disclose your personal data to our third-party suppliers, service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. for making deliveries to you, to fulfil your order/purchase).
We may also disclose your personal data to third parties:
in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers, resellers, suppliers will be one of the transferred assets; or
if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or
to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with to provide the Website.
Other than as set out above, and save in so far as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
Keeping your personal data up to date
If your personal details change you may update them by accessing the relevant page of the Website, or by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us using the contact details below.
We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
How long we keep your personal data
If you contact us using our website contact form, requesting general information about our services, we will hold personal data you choose to provide or that we may collect from you such as your name and e-mail address, for 1 year from our last point of contact, unless you register as a customer, reseller or supplier.
If you are engaged by one of our customers or resellers we will hold your contact information for the period that customer or reseller is registered with us and for 6 years after our last point of contact.
If you are engaged by one of our suppliers we will hold your contact information for we will hold your contact details for the period that supplier is registered with us and for 6 years after.
Any financial data (where you have made payment to us for our services) will be retained for 7 years in accordance with applicable tax laws.
Data such as IP addresses, traffic data, location data, weblogs and other communication data will be retained for 14 months from the date of collection.
Where we store your personal data
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). We will take all steps reasonably necessary to ensure that your data is held securely and in accordance with this Policy. Countries outside the EEA do not have the same data protection laws as the United Kingdom and EEA and we have therefore ensured that any of our suppliers who may transfer your personal data outside the EEA has put in place appropriate measures to protect your data, either by being a member of the US-EU Privacy Shield, or by entering into a European Commission approved contract (as permitted under Article 46(5) of the General Data Protection Regulation).
We will not otherwise transfer your personal data outside the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries. If you would like further information please contact Us (see ‘Contact’ below).
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
access to your personal data and to certain other supplementary information that this Policy is already designed to address
require Us to correct any mistakes in your information which We hold
require the erasure of personal data concerning you in certain situations
receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal data concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal data
otherwise restrict our processing of your personal data in certain circumstances
claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
email, call or write to Us
let Us have enough information to identify you (name, phone number, company name and e-mail address),
let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
let Us know the information to which your request relates.
HOW TO COMPLAIN
We hope that We can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner.
We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.
A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
The cookies We use include:
“Analytical” cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the 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.
“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.
“Functionality” cookies. 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).
“Targeting” cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed to our affiliates websites. We will use this information to make our Website, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to firstname.lastname@example.org or write to Us at Virtuoso Partners, Causeway House, 13 The Causeway, Teddington TW11 0JR.