BACKGROUND: VS Capital Limited understands that your
privacy is important to you and that you care about how your information is
used and shared online. We respect and value the privacy of everyone who visits
Our Site and will only collect and use information in ways that are useful to
you and in a manner consistent with your rights and Our obligations under the
law. This Policy applies to Our use of any and all data collected by us in
to occur upon your first use of Our Site. If you do not accept and agree with
1. Definitions and Interpretation In this Policy the following terms shall have the following meanings:
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
“Our Site” means this website, www.vitvo.com;
“UK and EU Cookie Law “means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
“We/Us/Our” means VS Capital Limited, a limited company registered in England under 07783075 whose registered address is 28-32 Belgrave Road, London, SW1V 1RG
2. Information About Us
2.1 Our Site, www.vitvo.com, is owned and operated by Us.
2.2 Our Data Protection Register registration number is Z3438254
4. What is Personal Data? Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights? Under the GDPR, you have the following rights, which we will always work to uphold:
b) The right to access the personal data we hold about you. The information below will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details on our website to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details on our website to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. For more information about ouruse of your personal data or exercising your rights as outlined above, please contact us using the details on our website. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
6. What Data Do We Collect? Some data will be collected automatically by Our Site, other data will only be collected if you voluntarily submit it, for example, when signing up for an Account or making an enquiry. Depending upon your use of Our Site, We may collect some or all of the following data:
6.2 date of birth;
6.4 business/company name
6.5 job title;
6.7 contact information such as email addresses and telephone numbers;
6.8 demographic information such as post code, preferences and interests;
6.9 financial information
6.10 IP address (automatically collected);
6.11 web browser type and version (automatically collected);
6.12 operating system (automatically collected);
7. How Do You Use My Personal Data? Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:· Providing and managing your Account;· Providing and managing your access to Our Site;· Personalizing and tailoring your experience on Our Site;· Supplying our productsand/or services to you. Your personal details are required in order for us to enter into a contract with you.· Personalizing and tailoring our products and/orservices for you.· Communicating with you. This may include responding to emails or calls from you.· Supplying you with information by email (you may unsubscribe or opt-out at any time by emailing or writing to us using the contact details on our web page).· Analyzing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience. With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on ourproducts AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
8. How Long Will You Keep My Personal Data? We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
9 How and Where Do You Store or Transfer My Personal Data? We will usually store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law. We may store or transfer some or all of your personal data in countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take steps with the person to whom we are transferring or storing data with to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR. We may also transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. Please contact us using the details on our website for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
10. Do You Share My Personal Data? We may share your personal data with other companies in our group. This includes subsidiaries and affiliated companies. We may sometimes contract with the third parties to supply certain productsand services or for the transfer or sale of loans or a loan portfolio. These may also include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold. If any of your personal data is required by a third party,as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law. If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as would be within the UK and under the GDPR. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11 What Happens If Our Business Changes Hands?
11.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
12.How Can You Control Your Data?
12.1 In addition to your rights under the GDPR, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails).
12.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
13 Your Right to Withhold Information.
13.1 You may access certain areas of Our Site without providing any data at all.
14. How Can You Access Your Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 16. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.