BACKGROUND:
“Vision Vantage Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers, business associates and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us:-
Vision Vantage Limited, Company registered in England under company number 12305541. Registered address: Kilsby & Williams, Cedar House, Hazell Drive, Newport, NP10 8FY.
Data Protection Officer: Shawn Thompson.
Email address: Shawn@visionvantageuk.com.
Telephone number: 01143190946
Postal address: Kilsby & Williams, Cedar House, Hazell Drive, Newport, NP10 8FY.
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
Address – Kilsby & Williams, Cedar House, Hazell Drive, Newport, NP10 8FY
Company Number – 12305541 ICO – ZA562947
3. What is Personal Data ?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) 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. The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always
work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 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 in Part 11 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 hold. Please contact us using the details in Part 11 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 withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) 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.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
Right to lodge a complaint with a supervisory authority – If we cannot deal with your complaint to your satisfaction you also have the right to complain to a relevant supervisory authority which include; The Information Commissioners Office; Wycliffe House, Water Lane, Wilmslow, SK9 5AF, or call: 0303 123 1113 or online at https://ico.org.uk/concernsshare/use your personal data. For more information about our use of your personal data or exercising your rights as outlined above,please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
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. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.
5. What Personal Data Do We Collect and How?
Depending upon your use of our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any “special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions or offences.
| Data Collected | Data Collected |
|---|---|
| Identity Information including name, title, date of birth, gender | Telecalling. |
| Contact information including address, email address, telephone number | Telecalling. |
| Business information including business name, job title, profession | Telecalling. |
| Data from third parties including contact information, profile information | Contract – We will also use 3rd parties to supply data subjects personal information to us this includes when data controllers supply us with information where you have completed a survey either online or by telephone where our brand is named on the controller’s privacy policy as a company with whom they share information. |
6. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
| What We Do | What Data We Use | Our Lawful Basis |
|---|---|---|
| Marketing or Surveys | Telephone Numbers | Legitimate interest |
| Supplying you with information by email or post that you have | Opt-in Data | Consent |
| Supplying you with information by SMS | Opt-in Data | Consent |
| Sharing data with 3rd parties | Information you have provided to us | Legitimate interest |
We use your data:-
• To enhance our services for the benefit of our customers including verification and validation.
• To help make the communication more relevant and contextual.
• To better understand how our customers interact with our services.
• To provide direct marketing communications which we think will be of interest to you.
• To determine the effectiveness of our and our clients promotional campaigns.
• To identify and prevent fraud.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose.
If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
Marketing Service Providers are companies who collect data from Data Controllers, such as ourselves, and help their clients tailor products and services which best suit your needs. They may also use your data for fraud prevention. The Marketing Services Providers we work with are strictly limited to only those organisations we have completed checks on and who will process your data in strict compliance with all laws, regulations and guidance with regard to Data Protection. We will share your data under strict licence terms with the Marketing Services Providers listed below, who like us, will use it to create products and services to help organisations better understand the likely characteristics of their customers; communicate with them more effectively; and find others like them across a range of marketing channels.
Our Marketing Service Providers include https://www.consumerlifestyles.co.uk/ , Aura Media Group Ltd https://www.auramediagroup.co.uk/privacy-policy, Perfect Ingenuity Ltd (https://perfectingenuity.com/privacypolicy/), Sky UK Ltd, Leads 365 Ltd (https://www.lead365.co.uk/privacy-policy/), 3 Dotz Consultancy Ltd, Interrog8 Ltd, ESB, Your Lotto Services, WhiteGold Media Ltd, Save Club La Costa UK Plc, Scottish Power Energy Retail Ltd, Dennis Publishing (UK) Ltd trading as Auto Express Magazine, Aditus Audience Acquisition ltd – Puzzled Magazine, Home Finance Advice Holdings Limited, Viva La Voucher, Tech Essence Limited, Health Care PMI Limited, Wordsearch Puzzle, Utilita Telesales Limited, TV & Satellite Week, Kairos Zenith, Kairos Peniculid, The Honey Group, Save Solar, Heat Seal Insulation Wall, Healthier Intermediaries Ltd, British Seniors Insurance Agency, Switch Experts, Access Financial Services, Lead Intelligence Limited, PFP Energy, Service Box Group Limited, CPS Advisory, Dignity Funeral, Virgin Media, Newhall Publishing, Bulb Energy, Candis Magazines, Niagara Healthcare, GreenStar Energy, Intelligent PMI, Dignity, Carphone Warehouse, Comfomatics, Dogs Trust, Greenspace, WSL Wills, Fight For Sight, Mortgage Advice Services, Octopus Energy Ltd, ESB Energy, The Mortgage Claim Centre, Repair and Assure, Homeshield Direct ltd, O2, Utilita Energy Limited, Boost Power, Together Energy, Shell Energy Retail Limited, Orbit Energy, Your Legacy Matters, We Plan Lifestyles, Home Appliance TV Care, The Honey Group and The Wills Associate.
Industry sectors: the following sectors are the industry types you can expect your data to be supplied to, depending on the answers given by you and your stated interests: automotive, charity, education, gaming, leisure, investments, loans, credit cards, insurance, politics, health/mobility, home improvements, wills, funeral plans, claims management (mis-sold ppi, packaged bank accounts, investments, credit card/bank charges, mortgages and pensions), mail order, market research, media, retail, telecoms, toiletries/cosmetics, travel, utilities. From time to time we also supply our data to these sectors via agencies/brokers. Your details may also be shared with we plan lifestyles. If any of your personal data is shared with 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, as described above in part 8. 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 it would be within the uk and under the data protection legislation, as explained above in part 8.
7. 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. Your personal data will therefore be kept for the following
periods (or, where there is no fixed period, the following factors will be used to determine
how long it is kept):
| Type of Data | How long do we keep it for ? |
|---|---|
| Identity Information including name, title, date of birth, gender | 12 Months. |
| Contact information including address, email address, telephone number | 12 Months. |
| Business information including business name, job title, profession | 12 Months.. |
8. How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and
securely as it would be within the UK and under the Data Protection Legislation as follows:
We share your data within the group of companies of which we are a part. Where this involves the
transfer of personal data outside the EEA, we ensure that personal data is protected by requiring
all companies within the group to follow the same rules with respect to personal data usage. These
are known as “binding corporate rules”. More information on binding corporate rules is available
from the European Commission.
Please contact us using the details below in Part 11 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
9. Do You Share My Personal Data?
If any of your personal data is shared with a third party, 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, as described above in Part 8.
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 it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
10. How can I access my Personal 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 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
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 10 days and, in any case, not more than 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.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Shawn Thompson:
Email address: Shawn@visionvantageuk.com.
Telephone number: 01143190946
Postal Address: Kilsby & Williams, Cedar House, Hazell Drive, Newport, NP10 8FY.
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on www.linklifestyle.co.uk. This Privacy Notice was last
updated on 16-07-2020
Address – Kilsby & Williams, Cedar House, Hazell Drive, Newport, NP10 8FY Company Number – 12305541 ICO – ZA562947