Product Privacy Policy

Last updated: 15 May 2019

Virtual Pricing Director Limited (“VPD”, “we” or “us”) respects your right to privacy.  This Privacy Notice explains who we are; how we collect, share and use personal information about you when you enquire about or otherwise use our Virtual Pricing Director product online or via the desktop icon installed on your computer (“Product”); and how you can exercise your privacy rights.  This Privacy Notice only applies to personal information that we collect through our Product.  For personal information that we collect when you use or interact with our website, please see our website privacy notice.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.

Contents

We recommend that you read this Privacy Notice in full to ensure you are fully informed.

1. What personal information does VPD collect and why?
2. Who does VPD share my personal information with?
3. Legal basis for processing personal information
4. Cookies and similar tracking technology
5. How does VPD keep my personal information secure?
6. International data transfers
7. Data retention
8. Your data protection rights
9. Updates to this Privacy Notice
10. How to contact us

What personal information does VPD collect and why?

The personal information that we may collect about you broadly falls into the following categories:

• Information that you provide voluntarily

Certain parts of our Product may ask you (or your employer) to provide personal information voluntarily: for example, we may ask you (or your employer) to provide us with contact details, such as your name, corporate email address, corporate telephone number, company name and company address.  We may use this information in order to facilitate our business sales to you (or your employer), to allow you (or your employer) to subscribe to marketing communications from us, and/or to enable you to submit enquiries to us.  Where you are authorised to use the Product by your employer, you will also have a unique password that enables you to access the Product.

We may use your personal information for the purposes of our general business management, including contract management: for example, to enable us to provide you (or your employer) with access to and use of our Product, or to check that you (or your employer) are using our Product in accordance with our terms and conditions.  We may also use this information to help us manage our daily business activities, such as to enable us to invoice you (or your employer) for our services; to manage any queries, complaints or claims relating to our Product; for product development purposes (to allow us to improve our Product and services or to develop new products or services); to help us conduct our business more effectively and to check the quality of our Product and services; or for research and development.

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

• Information that we collect automatically

When you use our Product, we may collect certain information automatically from your device.  In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

Although we do not collect this kind of information at the moment, in the future the types of information that we may collect automatically may include information like: your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information.  We may also collect information about how your device has interacted with our Product, including the pages accessed and links clicked.

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.

If we do start collecting this information, or using cookies, we will provide you with more information about how and why we do this at that time.

In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information.  However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

Who does VPD share my personal information with?

We may disclose your personal information to the following categories of recipients:

• to our group companies and third party services providers who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Product), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information;
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
• to any other person with your consent to the disclosure.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you (or your employer), (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.  In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to provide our Product to you (or your employer) and communicate with you (or your employer) as necessary to provide our Product and services; as well as for our legitimate commercial interests, for instance, when responding to your queries, managing our commercial relationship, improving our Product, undertaking marketing, or for the purposes of detecting or preventing illegal activities.  We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

Cookies and similar tracking technology

We do not currently use cookies and similar tracking technology (collectively, “Cookies”) in our Product to collect and use personal information about you, except as strictly necessary to enable the secure provision of our Product to you.  If this changes, we will let you know.

How does VPD keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you.  The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

Where you have a password, which enables you to access our Product, you are responsible for keeping this password secure and confidential.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident.  These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our Product servers, group companies and third party service providers are located in the European Economic Area. This means that when we collect your personal information we may process it in the European Economic Area.

In addition, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.

 

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your data protection rights

You have the following data protection rights:

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
• In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact our privacy officer using the following details:

[email protected]

The data controller of your personal information is Virtual Pricing Director Limited, a company registered in England under company number 10982080.