Table of contents
2. How is your personal data collected?
3. Explaining the legal bases we rely on to process personal data
5. Disclosures of your personal data
6. Payment information
7. International transfers
8. Data security
9. Data retention
10. Your legal rights
11. How to contact VCV about privacy
12. A little request from VCV to you
It also tells you about your privacy rights and how the law protects you.
Our website, apps and services aimed at business users. This website is not intended for children under the age of majority in their jurisdiction and we do not knowingly collect data relating to children.
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 collect a variety of information about our users and visitors to the VCV website. This personal data falls into these categories:
Identity Data includes title, first name, last name, username or similar identifier and your login/password. If you interact or login to our services with us through social media such as LinkedIn, this may include your user name.
Contact Data includes billing address, email address and telephone numbers.
Financial Data includes payment details.
Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
Profile Data includes your username and password, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).
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 website.
Usage Data includes information about how you use our website, apps and services.
Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as mobile identifiers.
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 website feature. To provide better content and service, VCV’s website uses the Google Analytics web analytics service. Please see Google’s privacy for more information. Google provides some additional privacy options described at http://www.google.com/policies/privacy/partners/with respect to Google Analytics cookies. To opt out from Google Analytics, you can download a plug-in from http://tools.google.com/dlpage/gaoptout.
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, using our services or by corresponding with us by phone, email or through chat or social media.
This includes personal data you provide when you:
Automated technologies or interactions. As you interact with us, including via the website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website.
Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:
Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to automated decision-making. Our clients will develop the questions for the chatbot to ask job applicants and based on the applicant’s answers and the clients’ response categorizations, the chatbot determines if the applicant will move on to additional interviews. Where our legal basis is consent, you have the right to withdraw consent any time but you may not be able to use all of our services as a result.
See Explaining the legal bases we rely on to process personal data to find out more about the types of lawful basis that we will rely on to process your personal data.
The table below shows you a description of all the ways we plan to use 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.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new customer||Identity
|Performance of a contract with you|
|To process and deliver the services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|Performance of a contract with you
Necessary for our legitimate interests (including to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
|Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity
|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 reorganization or group restructuring exercise)
|To deliver the services where you engage in a chatbot interview||Identity
Special (race, ethnicity)
|Performance of a Contract with you.|
|To use data analytics to improve our website, services, customer relationships and experiences||Technical Tracking
|Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business)|
|In order to resolve legal claims or disputes involving you or us||All relevant data categories, depending on the nature of the allegation or claim||Necessary to bring or defend a claim|
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.
If you ever have any questions about this, all you have to do is ask. See How to contact VCV about privacy below.
Cookies are a tool which we (and everyone one else who operates online) uses for advertising. That is just part of why cookies are used. Generally, they are pretty clever.
Cookies help our website and apps work better and provide lots of help in the background to make the process of being a VCV user a lot easier. You’d miss a lot of these things if they were gone – like it being easy to log in and move from page to page.
Other cookies collect information about how visitors use our website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and used to improve how our website works.
There are also cookies that allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features.
When you use our website, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It’s important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.
We may share personal data with the following categories third parties:
For example, we share personal data with the following specific third parties:
We also share data with third parties connected to advertising, retargeting and analytics. Please see Cookies above, including the cookie list, for more information about who those third parties are.
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.
VCV bills and collects payments offline.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed, such as encryption, firewalls, password protection, third party audits and other internal restrictions. 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.
We will only keep 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 unauthorized 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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a certain period of time after they stop being customers for tax purposes.
In some circumstances you can ask us to delete your data; see Your legal rights below for further information.
In some circumstances we may anonymize 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.
Please, read our Data retention policy.
If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:
These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.
If you wish to exercise any of the rights set out above, please contact us (see How to contact VCV about privacy).
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.
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.
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.
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.
If you need help about our services, or this website generally, please contact us [here]
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. You can do this by updating your account. Thank you.