PLEASE READ THE TERMS OF THIS POLICY CAREFULLY BEFORE USING THE APP

What’s in these terms?

This acceptable use policy sets out the content standards that apply when you upload content to our App, make contact with other users on our App, link to our App, or interact with our App in any other way,

Who we are and how to contact us

  1. VYPR is a mobile application (“App”) operated by VYPR Validation Technologies Limited (“We”). We are registered in England and Wales under company number 08589377 and have our registered office at 2 Hardman Boulevard, Manchester, England, M3 3AQ. Our VAT number is 173146613.

  2. We are a limited company.

To contact us, please email hello@vypr.it or telephone our customer service line on +44 (0) 161 694 6320.

By using our app you accept these terms:

  1. By using our App, you confirm that you accept the terms of this policy and that you agree to comply with them.

  2. If you do not agree to these terms, you must not use our App.

We recommend that you print a copy of these terms for future reference.

There are other terms that may apply to you:

  1. Our end user licence agreement also applies to your use of our App.

  2. We may make changes to the terms of this policy.

We may amend these terms from time to time. Every time you wish to use our App, please check these terms to ensure you understand the terms that apply at that time. These terms were most recently updated on 21st May 2018.

Prohibited uses

You may use our App only for lawful purposes.  

You may not use our App:

  • In any way that breaches any applicable local, national or international law or regulation.

  • In any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect.

  • For the purpose of harming or attempting to harm minors in any way.

  • To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards.

  • To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).

  • To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:

  • Not to reproduce, duplicate, copy or re-sell any part of our App in contravention of the provisions of our terms of website use.

  • Not to access without authority, interfere with, damage or disrupt:

  • any part of our App;

  • any equipment or network on which our App is stored;

  • any software used in the provision of our App; or

  • any equipment or network or software owned or used by any third party.

Interactive services

We may from time to time provide interactive services on our App, including, without limitation:

  • Chat rooms.

  • Bulletin boards.

Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).

We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on our App, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our App, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.

Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.

Content standards

These content standards apply to any and all material which you contribute to our App (Contribution), and to any interactive services associated with it.

The Content Standards must be complied with in spirit as well as to the letter. The standards apply to each part of any Contribution as well as to its whole.

We will determine, in our discretion, whether a Contribution breaches the Content Standards.

A Contribution must:

  • Be accurate (where it states facts).

  • Be genuinely held (where it states opinions).

  • Comply with the law applicable in England and Wales and in any country from which it is posted.

A Contribution must not:

  • Be defamatory of any person.

  • Be obscene, offensive, hateful or inflammatory.

  • Promote sexually explicit material.

  • Promote violence.

  • Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.

  • Infringe any copyright, database right or trade mark of any other person.

  • Be likely to deceive any person.

  • Breach any legal duty owed to a third party, such as a contractual duty or a duty of confidence.

  • Promote any illegal activity.

  • Be in contempt of court.

  • Be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety.

  • Be likely to harass, upset, embarrass, alarm or annoy any other person.

  • Impersonate any person, or misrepresent your identity or affiliation with any person.

  • Give the impression that the Contribution emanates from us, if this is not the case.

  • Advocate, promote, incite any party to commit, or assist any unlawful or criminal act such as (by way of example only) copyright infringement or computer misuse.

  • Contain a statement which you know or believe, or have reasonable grounds for believing, that members of the public to whom the statement is, or is to be, published are likely to understand as a direct or indirect encouragement or other inducement to the commission, preparation or instigation of acts of terrorism.

  • Contain any advertising or promote any services or web links to other apps.

Breach of this policy

When we consider that a breach of this acceptable use policy has occurred, we may take such action as we deem appropriate.  

Failure to comply with this acceptable use policy constitutes a material breach of the end user licence agreement upon which you are permitted to use our App, and may result in our taking all or any of the following actions:

  • Immediate, temporary or permanent withdrawal of your right to use our App.

  • Immediate, temporary or permanent removal of any Contribution uploaded by you to our App.

  • Issue of a warning to you.

  • Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.

  • Further legal action against you.

  • Disclosure of such information to law enforcement authorities as we reasonably feel is necessary or as required by law.

We exclude our liability for all action we may take in response to breaches of this acceptable use policy. The actions we may take are not limited to those described above, and we may take any other action we reasonably deem appropriate.

Which country’s laws apply to any disputes?

  1. If you are a consumer, please note that the terms of this policy, its subject matter and its formation are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.

  2. If you are a business, the terms of this policy, its subject matter and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

 

PLEASE READ THE TERMS OF THIS POLICY CAREFULLY BEFORE USING THE APP

What’s in these terms?

This acceptable use policy sets out the content standards that apply when you upload content to our App, make contact with other users on our App, link to our App, or interact with our App in any other way,

Who we are and how to contact us

  1. VYPR is a mobile application (“App”) operated by VYPR Validation Technologies Limited (“We”). We are registered in England and Wales under company number 08589377 and have our registered office at 2 Hardman Boulevard, Manchester, England, M3 3AQ. Our VAT number is 173146613.

  2. We are a limited company.

To contact us, please email hello@vypr.it or telephone our customer service line on +44 (0) 161 694 6320.

By using our app you accept these terms:

  1. By using our App, you confirm that you accept the terms of this policy and that you agree to comply with them.

  2. If you do not agree to these terms, you must not use our App.

We recommend that you print a copy of these terms for future reference.

There are other terms that may apply to you:

  1. Our end user licence agreement also applies to your use of our App.

  2. We may make changes to the terms of this policy.

We may amend these terms from time to time. Every time you wish to use our App, please check these terms to ensure you understand the terms that apply at that time. These terms were most recently updated on 21st May 2018.

Prohibited uses

You may use our App only for lawful purposes.  

You may not use our App:

  • In any way that breaches any applicable local, national or international law or regulation.

  • In any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect.

  • For the purpose of harming or attempting to harm minors in any way.

  • To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards.

  • To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).

  • To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:

  • Not to reproduce, duplicate, copy or re-sell any part of our App in contravention of the provisions of our terms of website use.

  • Not to access without authority, interfere with, damage or disrupt:

  • any part of our App;

  • any equipment or network on which our App is stored;

  • any software used in the provision of our App; or

  • any equipment or network or software owned or used by any third party.

Interactive services

We may from time to time provide interactive services on our App, including, without limitation:

  • Chat rooms.

  • Bulletin boards.

Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).

We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on our App, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our App, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.

Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.

Content standards

These content standards apply to any and all material which you contribute to our App (Contribution), and to any interactive services associated with it.

The Content Standards must be complied with in spirit as well as to the letter. The standards apply to each part of any Contribution as well as to its whole.

We will determine, in our discretion, whether a Contribution breaches the Content Standards.

A Contribution must:

  • Be accurate (where it states facts).

  • Be genuinely held (where it states opinions).

  • Comply with the law applicable in England and Wales and in any country from which it is posted.

A Contribution must not:

  • Be defamatory of any person.

  • Be obscene, offensive, hateful or inflammatory.

  • Promote sexually explicit material.

  • Promote violence.

  • Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.

  • Infringe any copyright, database right or trade mark of any other person.

  • Be likely to deceive any person.

  • Breach any legal duty owed to a third party, such as a contractual duty or a duty of confidence.

  • Promote any illegal activity.

  • Be in contempt of court.

  • Be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety.

  • Be likely to harass, upset, embarrass, alarm or annoy any other person.

  • Impersonate any person, or misrepresent your identity or affiliation with any person.

  • Give the impression that the Contribution emanates from us, if this is not the case.

  • Advocate, promote, incite any party to commit, or assist any unlawful or criminal act such as (by way of example only) copyright infringement or computer misuse.

  • Contain a statement which you know or believe, or have reasonable grounds for believing, that members of the public to whom the statement is, or is to be, published are likely to understand as a direct or indirect encouragement or other inducement to the commission, preparation or instigation of acts of terrorism.

  • Contain any advertising or promote any services or web links to other apps.

Breach of this policy

When we consider that a breach of this acceptable use policy has occurred, we may take such action as we deem appropriate.  

Failure to comply with this acceptable use policy constitutes a material breach of the end user licence agreement upon which you are permitted to use our App, and may result in our taking all or any of the following actions:

  • Immediate, temporary or permanent withdrawal of your right to use our App.

  • Immediate, temporary or permanent removal of any Contribution uploaded by you to our App.

  • Issue of a warning to you.

  • Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.

  • Further legal action against you.

  • Disclosure of such information to law enforcement authorities as we reasonably feel is necessary or as required by law.

We exclude our liability for all action we may take in response to breaches of this acceptable use policy. The actions we may take are not limited to those described above, and we may take any other action we reasonably deem appropriate.

Which country’s laws apply to any disputes?

  1. If you are a consumer, please note that the terms of this policy, its subject matter and its formation are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.

  2. If you are a business, the terms of this policy, its subject matter and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

Supplemental Terms of

VYPR Validation Technologies Limited, relating to VYPR App.

1. Your use of the VYPR application (“App”) is subject to the supplemental terms of use of the developer, VYPR Validation Technologies Limited (who is referred to in this document as “VYPR”). These supplemental terms are set out below ( and are referred to in this document as “Supplemental Terms”).

2. Prior to downloading and/or using the App, you must accept these Supplemental Terms by ticking the “I accept” box via the applicable platform store ( Apple or Google). Your continued use of the App will in any event signify your acceptance of these Supplemental Terms. These Supplemental Terms are supplemental to any applicable standard Apple or Google EULA and any other applicable Apple or Google terms of service that are brought to your attention prior to or at the time of your accessing, downloading or using the App (together “Platform EULA Terms”). Nothing in these Supplemental Terms will supersede or override the applicable Platform EULA Terms which will continue to apply in addition to these Supplemental Terms, save that in the event that there is any conflict between the applicable Platform EULA Terms and these Supplemental Terms, the former shall prevail.

3. You shall not use the App for any use other than your own personal use. Use of the App for business purposes is strictly prohibited. The content of the App and any information contained in or apparent from the App, including without limit, relating to any products or services or retailer, or any questions or steers relating to products or services (together referred to as “Confidential Information”) are strictly confidential and shall be used only for the purposes of interacting with or using the App. You undertake to VYPR to keep such Confidential Information confidential at all times and not to disclose to any other person, save as may be required by law. You hereby INDEMNIFY and hold harmless VYPR and its directors, officers, group companies and affiliates, against any losses, demands, claims, liabilities and costs (including without limit legal costs on an indemnity basis) incurred or suffered as a result of your failure to comply with these Supplemental Terms.

4. If you divulge any of the Confidential Information to any third party or use for business purposes in breach of these Supplemental Terms, you are at risk of VYPR taking such action as is necessary to protect its rights, including without limit, Court proceedings to claim damages and costs. You acknowledge that damages alone would not be an adequate remedy for the breach of any of the provisions of these Supplemental Terms.  Accordingly, without prejudice to any other rights and remedies VYPR may have, VYPR shall be entitled to the granting of equitable relief (including without limitation injunctive relief) concerning any threatened or actual breach of any of the provisions of these Supplemental Terms.

5. Your obligations under these Supplemental Terms are in addition to any other obligations which you may have under statute, common law or otherwise.

6. VYPR makes NO WARRANTY regarding the accuracy, completeness, functionality or efficacy of the Confidential Information and all implied warranties, conditions or other terms or hereby excluded to the fullest extent permitted by law.

7. If any provision of these Supplemental Terms is found by any competent authority or a court of law to be invalid or unenforceable for any reason, the remainder of these Supplemental Terms shall continue in full force and effect.

8. These Supplemental Terms shall be governed by and construed in accordance with the laws of England and Wales and you agree to the exclusive jurisdiction of the English courts.

Introduction

Welcome to the VYPR Validation Technologies Limited’s privacy notice.

This privacy notice (together with our end-user licence agreement (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of Vypr mobile application software (App) and any of the services accessible through the App (Services).

VYPR Validation Technologies Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you use the App (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how VYPR Validation Technologies Limited collects and processes your personal data through your use of this App, including any data you may provide through this App when you create an account.

This App is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

We have outsourced our Data Protection function to Priviness Ltd who can be contacted at dpo@priviness.eu.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 21 May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The data we collect about you

Personal data, or personal information, 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes name, email address, gender, date of birth, PayPal email

  • Contact Data includes email address.

  • Financial Data includes PayPal details.

  • Transaction Data includes details about payments to you and other details of services you have provided to us.

  • 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 App.

  • Profile Data includes your username and password, services provided by you, your interests, preferences, feedback and survey responses.  

  • Usage Data includes information about how you use our App.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • create an account on our App;

  • enter a competition, promotion or survey; or

  • give us some feedback.

  • Automated technologies or interactions. As you interact with our App, we may automatically collect Technical Data about your equipment, app usage and patterns. We collect this personal data by using in app analytics, server logs and other similar technologies.

  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:-

    • Technical Data from analytics providers such as Google based outside the EU;

    • Contact Data from providers of technical, payment and delivery services such as PayPal based outside the EU.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

The types of lawful basis that we will rely on to process your personal data are:-

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to 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.

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.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new user(a) Identity
(b) Contact
Performance of a contract with you
To manage points accrual and redemption(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Communications
(a) Performance of a contract with you
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Communications
(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 enable you to complete a survey(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
(to study how customers use our products/services,
to develop them and grow our business)
To administer and protect our business and this App (including
troubleshooting, data analysis, testing, system maintenance,
support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for
running our business, provision of administration
and IT services, network security, to prevent fraud
and in the context of a business reorganisation or
group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our App, products/services,
marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define
types of customers for our products and services,
to keep our App updated and relevant, to develop
our business and to inform our marketing strategy)
To supply surveys that may be of interest to you(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop
our products/services and grow our business)

We strive to provide you with choices regarding certain personal data uses and how and when we contact you.

Promotional offers from us

You will receive marketing communications from us if you have requested information from us or provided feedback to us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time switching off notifications from the App in your device and you can unsubscribe from emails by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of completing surveys within App.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

External Third Parties

  • Service providers who provide IT and system administration services.

  • Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

  • Our customers upon whose products you have provided feedback.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Data security

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.

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.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may 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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data 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 data. This enables you to ask us to delete or remove personal data 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 data 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 data to comply with local law. Note, however, that we may not always be able to comply with your request of 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 data where we are relying on a legitimate interest (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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data 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 data. This enables you to ask us to suspend the processing of your personal data 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 data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data 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 data. 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 products or 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.

No fee usually required

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 may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. 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.