This policy explains how the Virtual Office Assistant collects and processes your personal data through your use of this website or when you purchase our services. This website is not intended for children and we do not knowingly collect data relating to children.
Address to: Ms. C. Magdinier, www.Virtual-Office-Assistant.co.uk
Email address: email@example.com.
Postal address: 15 Fidlers Walk, Wargrave, Reading, Berkshire RG10 8BA United Kingdom
Telephone number: 0844 884 1814
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 appreciate the chance to deal with any concerns before you approach the ICO, so please contact us in the first instance.
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
Virtual-Office-Assistant.co.uk is the trading name of a business run by Christelle Magdinier, who is the controller and responsible for your personal data. In this policy, “we”, “us” or “our” refers to Virtual-Office-Assistant.co.uk.
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 (anonymised).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows (being typical examples):
- Identity: first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact: billing address, delivery address, email address and telephone numbers.
- Financial: bank account and payment card details.
- Transaction: details about payments to and from you and other details of services you have purchased from us.
- Technical: internet protocol (IP) address, 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.
- Profile: your online usernames and passwords, purchases or orders made by you, your interests, preferences, feedback and survey responses, information about your family and personal or professional contacts.
- Usage: information about how you use our website and services.
- Marketing and Communications: your preferences in receiving marketing from us and our third parties and your communication preferences.
In exceptional cases only and under your explicit instructions, we may collect Special Categories of Personal Data about you – such as details concerning your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data. We do not collect any information about criminal convictions and offences.
HOW YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us Identity, Contact, Financial, Profile, Marketing and Communications Data by corresponding directly with us by email, through our website or other online media, by post, phone, or otherwise. This particularly includes personal data you provide when you supply us with information or instructions required for the services you have asked us to provide.
- Automated technologies or interactions. As you interact with our website, the provider of our website will automatically collect Technical Data about your equipment, browsing actions and patterns. This personal data is collected by using cookies and other similar technologies, but is not used by us. See section on Cookies below.
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 obligation.
See Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before 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.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased our services and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time by phone or email.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it. 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.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with third parties acting as data processors or joint controllers for the permitted purposes explained above. These third parties may include:
- Service providers who supply IT and system administration services.
- Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to handle it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own separate purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not generally transfer your personal data to third parties or locations outside of the EEA. We may transfer some of your data to service providers outside of the EEA where this is strictly necessary to meet your instructions – for example, in order to book travel or hotels.
The provider of our website and IT infrastructure may use external third parties or servers based outside the EEA, so that some processing of your personal data could involve a transfer of data outside the EEA. Where there is such a transfer, at least one of the following safeguards is implemented to protect your personal data and rights:
- Your personal data will only be processed in countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Specific contracts may be used, as approved by the European Commission, which give personal data the same protection it has within the EU. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where data is processed by parties in the United States of America, data may be transferred to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 will promptly notify you and any applicable regulator of any suspected data breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see the next section below for further information.
YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data. Please see further detail in the Glossary below to find out more about these rights. 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). If your request is clearly unfounded, repetitive or excessive, we have the legal right to refuse or, alternatively, we may charge a reasonable fee in order to meet your request.
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 could 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
YOUR LEGAL RIGHTS
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 entitles you to object to processing on this ground because 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:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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.