This Notice sets out our commitments to safeguarding your privacy and establishes how we will collect, process and store your Personal Data when using the Website.
Within this policy:
‘Content’ means any information, articles or images included within the Website;
‘Personal Data’ means any information in any format or medium, from which you can be personally identified;
‘we’, ‘us’ or ‘our’ means VINCIDASH LIMITED, a company incorporated in England with a registered office at 483 Green Lanes, London, England, N13 4BS and a company registration number of 12860804.
‘Website’ means www.vinciDASH.com
‘you’ or ‘your’ means the visitor or user of the Website;
We are providing this information as part of our on-going efforts to provide transparency and fairness by
a) ensuring that you have all the information regarding your privacy when using the Website; and
b) to comply with our obligations and your rights created by applicable law.
We pride ourselves on keeping up to date with regard to advances in technology and legal developments which can result in us needing to change this Privacy Notice, if we make any changes we shall make the new notice available on the Website which shall apply from the date of publication so you are encouraged to revisit this Notice periodically to ensure that you agree to the version that is current at the time of your visit.
Your trust is important to us and we want to be clear and transparent about
a) What Personal Data we collect;
b) How we use that Personal Data;
c) Who we share the Personal Data with;
d) How we store and retain your Personal Data;
e) Your rights in respect of that Data.
Whether or not you are personally identifiable from the data that we gather, store, or process you can be assured the data will only be used in accordance with this notice.
You will be asked to agree to this Privacy Notice, if you do not agree with anything within this Privacy Notice, you must not use our Website.
1. Your Personal Data
1.1. We will only gather, collect, process, or store any Personal Data –
a) with a lawful purpose;
b) that is necessary for processing an enquiry;
c) that is necessary to deliver the website to the device used by you;
d) to take the necessary steps to enter into and in the performance of a contract with you;
e) that is necessary for the administration of an account if you register with the Website;
f) for the recording of a financial transaction;
g) for internal records that we are legally obliged to keep;
h) to deal with complaints, disputes and legal actions;
i) where necessary to protect the vital interest of you or another person;
j) to send commercial communications from us (including newsletters and notifications), where you request or consent to such communications;
k) to send commercial communications from selected partners, associates, or affiliates only where you expressly request or consent to such communications.
2. Use of the Website
2.1. When visiting the Website, we may collect the following information –
a) the country from where you gain access to the Website;
b) the browser used by your device;
c) the operating system used by your device;
d) the screen resolution and other settings of the device you use;
e) the web pages that you visit or access;
f) the length of time you spend on a webpage;
g) the referral source, if any (the way how you arrived at the Website).
2.2. This information is anonymised and you cannot be personally identified from it, therefore it is not classified as Personal Data.
2.3. The information is used with a legitimate interest or consent to
a) generate website usage reports and statistics;
b) maintain a Website that is user friendly and compatible with popular equipment and software;
c) analyse and maintain the security of the Website and help identify inappropriate or malicious use.
3.1. If you make an enquiry about the Website or its Content, you may be required to provide us with your name, telephone number and an email address.
3.2. This information is processed with
a) A legitimate interest – in order that we can respond to your enquiry.
4.1. If you register with us to use a restricted area or access any software or apps we may require your name, address, telephone number and email address, you will also need to create a username and password.
4.2. we will use your Personal Data
a) For the administration and performance of the account;
b) For the recording of any financial transactions;
c) For internal records that we are legally obliged to keep;
d) To deal with complaints, disputes and legal actions;
e) To detect miss-use;
f) Where necessary to protect the vital interest of you or another person;
g) To send commercial communications from us except where you opt-out of receiving such communications.
5. Sharing your Personal Data
5.1. We may use and share your Personal Data with our employees, officers, agents, consultants, suppliers, or subcontractors insofar as reasonably necessary
a) For dealing with an enquiry or administering a registration;
b) For performance of a contractual obligation;
c) To the extent that we are required to do so by law;
d) In connection with any legal proceedings or prospective legal proceedings;
e) To establish, exercise or defend our legal rights;
f) With the purchaser (or prospective purchaser) of any business, asset, or account which we are (or are contemplating) selling.
5.2. We may also engage other businesses for website, IT or analytic support and maintenance who may, whilst performing their services have access to your Personal Data. These businesses will be working under a contract for services that contain strict conditions in relating to accessing Personal Data and will be subject to confidentiality undertakings.
6. Automated Processing
6.1. We shall not use automated processing of your Personal Data to form or make decisions except where authorised or required by law (for example for the detection of fraud or tax evasion); or you have given your express consent. If we use automated processing you are entitled to request details of the automated process.
7. Data Security
7.1. We will take reasonable technical and organisational precautions to prevent the loss, misuse, or alteration of Personal Data, including
a) storing of data on a secure, password protected and firewall protected device;
b) limiting access to data to only personnel who need access for the performance of a contract or the administration and management of an account.
8. Data transfers outside the EU
8.1. We shall not generally transfer or process any personal data outside the boundaries of the E.U. In the event that any data is transferred outside of the E.U. we shall inform you of the countries where the data takes place and ensure that the county has sufficient security measures and guarantees in place to protect the security of your Personal Data.
9. Data retention
9.1. Personal Data shall be retained for as long as necessary to fulfil the purpose which it was collected.
9.2. We may retain Personal Data for longer than is necessary for the purpose which it was collected to comply with a legal obligation or where we may need to exercise or defend our legal rights which means the some information may be retained for up to six years.
10. Your rights
10.1. You have the right to know
a) the identity and contact details of the Data Controller and Data Protection Officer (where applicable);
b) To know the purpose and legal basis for processing your Personal Data, and where processing is based on the legitimate interests of the Data Controller, what those legitimate interest are;
c) To know whether your Personal Data is transferred or processed beyond the EU and that appropriate safeguards are in place.
d) The right to access your Personal Data
e) The right to erase Personal Data.
f) The right to restrict processing.
g) The right to portable data.
h) The right to withdraw consent
i) The right to complain.
10.2. The right of access.
a) You may require us to provide you with any Personal Data we hold about you. To obtain a copy of any Personal Data we hold contact the Data Controller.
b) The Personal Data will be provided free of charge except where a request is manifestly unfounded or excessive (for example it is a repetitive request, or where we need to process large amounts of data) in which case we shall make a charge for our reasonable administrative costs in dealing with the request or refuse to respond but we must provide a justifiable reason for refusing to respond.
c) We shall provide the requested Personal Data within one month of receipt of the request, however where there is a substantial amount of information or it is difficult to collate we may extend this timeframe by one month by providing you notice.
d) As we take the issue of protecting your Personal Data seriously, we follow strict storage and disclosure procedures which mean that we may occasionally require proof of identity from you prior to disclosing such information.
10.3. The right to erase Personal Data
a) You have the right in certain circumstances to instruct us to erase your Personal Data where
i. The Personal Data is no longer necessary in relation to the purpose for which it was originally collected/processed;
ii. You withdraw your consent;
iii. You object to the processing and there is no overriding legitimate interest for continuing the processing;
iv. The Personal Data was unlawfully processed or obtained;
v. The Personal Data must be erased in order to comply with a legal obligation;
vi. The Personal Data is processed in relation to the offer of information services to a child.
b) Where you have the right and you issue an instruction to erase your Personal Data we shall use all reasonable efforts to
i. Inform all third parties to whom we have disclosed your Personal Data of the requirement to erase your Personal Data which they hold;
ii. In the event that your Personal Data has been published online we shall endeavour to ensure that any links or references are also removed, however due to the caching of information it may take same time before the Data is no longer visible or available, for example in search engine;
c) We may refuse to erase your Personal Data only
i. to exercise the right of freedom of expression and information;
ii. to comply with a legal obligation or for the performance of a public interest task or exercise of official authority;
iii. for public health purposes in the public interest;
iv. archiving purposes in the public interest, scientific research historical research or statistical purposes; or
v. the exercise or defence of legal claims.
10.4. The right to restrict processing
a) We shall, upon your request, restrict the processing of your Personal Data if the following circumstances arise
i. Where you contest the accuracy of the Personal Data we shall restrict the processing until we have verified the accuracy of the Personal Data.
ii. Where you have objected to the processing where it was necessary for the performance of a public interest task or purpose of legitimate interests, and we are considering whether our legitimate grounds override your grounds.
iii. When processing is unlawful and you oppose erasure and you request restriction instead.
iv. If we no longer need the Personal Data but you require the information to establish, exercise or defend a legal claim.
b) Where processing of your Personal Data is restricted, the information shall be stored but no further processing shall occur.
c) We shall inform any third party to whom we disclosed your Personal Data that the Information is restricted.
d) We shall inform you when and restricted period comes to an end.
10.5. The right to portable data
a) Any Personal Data where the lawful purpose for processing is consent or for the performance of a contract which is stored by us electronically we shall hold that Personal Data in a portable format (readable in a format that will be commonly used on other computer systems) and we shall provide this information to you or directly to another organisation (where technically feasible) upon your request.
10.6. The right to complain.
a) If you are not happy with the way we collect or store your Personal Data you can make a complaint to the Information Commissioners Office, however we would appreciate you contacting us first to give us the opportunity to provide an explanation or put things right.
10.7. The right to withdraw consent
a) If you provide your consent to process your Personal Data in a particular way, you may withdraw your consent at any time by informing the Data Controller at the address at the bottom of this notice.
b) Upon receipt of a notice withdrawing your consent to process your Personal Data we shall stop processing the Data except:
i. Where is it necessary for the performance of a contract.
ii. Where there are compelling legitimate grounds for the processing, which override your interests, rights and freedoms; or
iii. the processing is for the establishment, exercise, or defence of legal claims; or
iv. where the processing of the Personal Data is carried out under an obligation in law.
You can contact us regarding any aspect of the collection, use or storage of your Personal Data at [email protected]