Privacy Notice

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors, service  users, individual customers and customer personnel.

1.2 This policy applies where we are acting as a data controller with respect to  the personal data of such persons; in other words, where we determine the  purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly  necessary for the provision of our website, our customers websites and  services, we will ask you to consent to our use of cookies when you first visit  our website.

1.4 In this policy, "we", "us" and "our" refer to VOYSE data controller. For more  information about us, see Section 20.

2. The personal data that we collect

2.1 In this Section 2 we have set out the general categories of personal data that  we process and, in the case of personal data that we did not obtain directly  from you, information about the source and specific categories of that data.

2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number,  postal address and/or social media account identifiers. If you log into our  website using a social media account, we will obtain elements of the contact  data from the relevant social media account provider.

2.3 We may process your website user account data ("account data"). The  account data may include your account identifier, name, email address, account creation and modification dates, website settings and marketing  preferences. If you log into our website using a social media account, we will  obtain elements of the account data from the relevant social media account  provider.

2.4 We may process your information included in your personal profile on our  website ("profile data"). The profile data may include your name, address,  telephone number, email address, profile pictures, gender, date of birth,  salary, professional skills and experience, interests and hobbies, educational  details and employment details. The source of the profile data is you and/or  your employer. If you log into our website using a social media account, we  will obtain elements of the profile data from the relevant social media account  provider.

2.5 We may process information relating to our customer relationships ("customer relationship data"). The customer relationship data may  include your name, the name of your business or employer, your job title or  role, your contact details, your classification / categorisation within our  customer relationship management system and information contained in or  relating to communications between us and you, or between us and your  employer. The source of the customer relationship data is you and/or your  employer.

 

2.6 We may process information contained in or relating to any communication  that you send to us or that we send to you ("communication data"). The  communication data may include the communication content and metadata  associated with the communication. Our website will generate the metadata  associated with communications made using the website contact forms.

2.7 We may process data about your use of our website and services ("usage  data"). The usage data may include your IP address, geographical location,  browser type and version, operating system, referral source, length of visit,  page views and website navigation paths, as well as information about the  timing, frequency and pattern of your service use. The source of the usage  data is our analytics tracking system.

2.8 Please do not supply any other person's personal data to us, unless we  prompt you to do so.

3. Purposes of processing and legal bases

3.1 In this Section 3, we have set out the purposes for which we may process  personal data and the legal bases of the processing.

3.2 Operations - We may process your personal data for the purposes of  operating our website and associated websites, the processing and fulfilment  of orders, providing our services, supplying our goods, generating invoices,  bills and other payment-related documentation, and credit control. The legal  basis for this processing is our legitimate interests, namely the proper  administration of our website, services and business OR the performance of a  contract between you and us and/or taking steps, at your request, to enter  into such a contract.

3.3 Relationships and communications - We may process contact data,  account data, customer relationship data, transaction data and/or  communication data for the purposes of managing our relationships,  communicating with you (excluding communicating for the purposes of direct  marketing) by email, SMS, post, fax and/or telephone, providing support  services and complaint handling. The legal basis for this processing is our  legitimate interests, namely communications with our website visitors, service  users, individual customers and customer personnel, the maintenance of our  relationships, enabling the use of our services, and the proper administration  of our website, services and business.

3.5 Personalisation - We may process account data, service data and/or usage  data for the purposes of personalising the content and advertisements that  you see on our website and through our services to ensure that you only see  material that is relevant to you. The legal basis for this processing is consent OR our legitimate interests, namely offering the best possible experience for  our website visitors and service users OR the performance of a contract  between you and us and/or taking steps, at your request, to enter into such a  contract.

3.6 Direct marketing - We may process contact data, account data, profile data,  customer relationship data and/or transaction data for the purposes of  creating, targeting and sending direct marketing communications by email,  SMS, post and/or fax and making contact by telephone for marketing-related  purposes. The legal basis for this processing is consent OR our legitimate  interests, namely promoting our business and communicating marketing  messages and offers to our website visitors and service users.

 

3.7 Research and analysis - We may process usage data, service data and/or  transaction data for the purposes of researching and analysing the use of our  website and services, as well as researching and analysing other interactions  with our business. The legal basis for this processing is consent OR our  legitimate interests, namely monitoring, supporting, improving and securing  our website, services and business generally.

3.8 Record keeping - We may process your personal data for the purposes of  creating and maintaining our databases, back-up copies of our databases and  our business records generally. The legal basis for this processing is our  legitimate interests, namely ensuring that we have access to all the  information we need to properly and efficiently run our business in  accordance with this policy.

3.9 Security - We may process your personal data for the purposes of security  and the prevention of fraud and other criminal activity. The legal basis of this  processing is our legitimate interests, namely the protection of our website,  services and business, and the protection of others.

3.10 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance  coverage, managing risks and/or obtaining professional advice. The legal  basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.11 Legal claims - We may process your personal data where necessary for the  establishment, exercise or defence of legal claims, whether in court  proceedings or in an administrative or out-of-court procedure. The legal basis  for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.12 Legal compliance and vital interests - We may also process your personal  data where such processing is necessary for compliance with a legal  obligation to which we are subject or in order to protect your vital interests or  the vital interests of another natural person.

4. International transfers of your personal data

6.1 In this Section 6, we provide information about the circumstances in which  your personal data may be transferred to a third country under UK data  protection law OR EU data protection law OR UK and/or EU data protection  law.

6.2 We may transfer your personal data from the European Economic Area (EEA)  to the UK and process that personal data in the UK for the purposes set out in  this policy, and may permit our suppliers and subcontractors to do so, during  any period with respect to which the UK is not treated as a third country  under EU data protection law or benefits from an adequacy decision under EU  data protection law; and we may transfer your personal data from the UK to  the EEA and process that personal data in the EEA for the purposes set out in  this policy, and may permit our suppliers and subcontractors to do so, during  any period with respect to which EEA states are not treated as third countries  under UK data protection law or benefit from adequacy regulations under UK  data protection law.

6.3 We and our other group companies have offices and facilities in The UK. The  competent data protection authorities have made an adequacy determination  with respect to the data protection laws of each of these countries. Transfers  to each of these countries will be protected by appropriate safeguards,

 

namely the use of standard data protection clauses adopted or approved by  the competent data protection authorities.

6.4 The hosting facilities for our website are situated in UK, Ireland & USA. The  competent data protection authorities have made an adequacy determination  with respect to the data protection laws of each of these countries. Transfers  to all of these countries will be protected by appropriate safeguards, namely  the use of standard data protection clauses adopted or approved by the  competent data protection authorities, a copy of which you can obtain from  info@voyse.io 

7. Retaining and deleting personal data

7.1 This Section 7 sets out our data retention policies and procedures, which are  designed to help ensure that we comply with our legal obligations in relation  to the retention and deletion of personal data.

7.2 Personal data that we process for any purpose or purposes shall not be kept  for longer than is necessary for that purpose or those purposes.

7.3 We will retain your personal data as follows:

(a) contact data will be retained for a minimum period of two months following the date of the most recent contact between you and us, and  for a maximum period of 12 months following that date;

(b) account data will be retained for a minimum period of two months following the date of the most recent contact between you and us, and  for a maximum period of 12 months following that date;

(c) profile data will be retained for a minimum period of two months following the date of the most recent contact between you and us, and  for a maximum period of 12 months following that date;

(d) customer relationship data will be retained for a minimum period of two  months following the date of the most recent contact between you and  us, and for a maximum period of 12 months following that date;

(e) service data will be retained for a minimum period of two months following the date of the most recent contact between you and us, and  for a maximum period of 12 months following that date;

(f) transaction data will be retained for a minimum period of two months following the date of the most recent contact between you and us, and  for a maximum period of 12 months following that date;

(g) communication data will be retained for a minimum period of two  months following the date of the most recent contact between you and  us, and for a maximum period of 12 months following that date;

(h) usage data will be retained for a minimum period of two months following the date of the most recent contact between you and us, and  for a maximum period of 12 months following that date;

7.6 Notwithstanding the other provisions of this Section 7, we may retain your  personal data where such retention is necessary for compliance with a legal  obligation to which we are subject, or in order to protect your vital interests  or the vital interests of another natural person.

 

8. Security of personal data

8.1 We will take appropriate technical and organisational precautions to secure  your personal data and to prevent the loss, misuse or alteration of your  personal data.

8.2 We will store your personal data on secure servers, personal computers and  mobile devices, and in secure manual record-keeping systems.

8.3 The following personal data will be stored by us in encrypted form: your  name, contact information, password(s) and cardholder data.

8.4 Data relating to your enquiries and financial transactions that is sent from  your web browser to our web server, or from our web server to your web  browser, will be protected using encryption technology.

8.5 You acknowledge that the transmission of unencrypted (or inadequately  encrypted) data over the internet is inherently insecure, and we cannot  guarantee the security of data sent over the internet.

8.6 You should ensure that your password is not susceptible to being guessed,  whether by a person or a computer program. You are responsible for keeping  the password you use for accessing our website confidential and we will not  ask you for your password (except when you log in to our website).

9. Your rights

9.1 In this Section 9, we have listed the rights that you have under data  protection law.

9.2 Your principal rights under data protection law are:

(a) the right to access - you can ask for copies of your personal data;

(b) the right to rectification - you can ask us to rectify inaccurate  personal data and to complete incomplete personal data;

(c) the right to erasure - you can ask us to erase your personal data;

(d) the right to restrict processing - you can ask us to restrict the  processing of your personal data;

(e) the right to object to processing - you can object to the processing  of your personal data;

(f) the right to data portability - you can ask that we transfer your  personal data to another organisation or to you;

(g) the right to complain to a supervisory authority - you can  complain about our processing of your personal data; and

(h) the right to withdraw consent - to the extent that the legal basis of  our processing of your personal data is consent, you can withdraw that  consent.

9.3 These rights are subject to certain limitations and exceptions. You can learn  more about the rights of data subjects by visiting  

https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-

 

recommendations-best-practices_en and https://ico.org.uk/for

organisations/guide-to-data-protection/guide-to-the-general-data-protection regulation-gdpr/individual-rights/.

9.4 You may exercise any of your rights in relation to your personal data by  written notice to us, using the contact details set out below.

OR

9. Your rights

9.1 In this Section 9, we have summarised the rights that you have under data  protection law. Some of the rights are complex, and not all of the details have  been included in our summaries. Accordingly, you should read the relevant  laws and guidance from the regulatory authorities for a full explanation of  these rights.

9.2 Your principal rights under data protection law are:

(a) the right to access - you can ask for copies of your personal data;

(b) the right to rectification - you can ask us to rectify inaccurate  personal data and to complete incomplete personal data;

(c) the right to erasure - you can ask us to erase your personal data;

(d) the right to restrict processing - you can ask us to restrict the  processing of your personal data;

(e) the right to object to processing - you can object to the processing  of your personal data;

(f) the right to data portability - you can ask that we transfer your  personal data to another organisation or to you;

(g) the right to complain to a supervisory authority - you can  complain about our processing of your personal data; and

(h) the right to withdraw consent - to the extent that the legal basis of  our processing of your personal data is consent, you can withdraw that  consent.

9.3 You have the right to confirmation as to whether or not we process your  personal data and, where we do, access to the personal data, together with  certain additional information. That additional information includes details of  the purposes of the processing, the categories of personal data concerned  and the recipients of the personal data. Providing the rights and freedoms of  others are not affected, we will supply to you a copy of your personal data.  The first copy will be provided free of charge, but additional copies may be  subject to a reasonable fee. You can access your personal data by request at  info@voyse.io 

9.4 You have the right to have any inaccurate personal data about you rectified  and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

9.5 In some circumstances you have the right to the erasure of your personal  data without undue delay. Those circumstances include: the personal data are  no longer necessary in relation to the purposes for which they were collected  or otherwise processed; you withdraw consent to consent-based processing;

 

you object to the processing under certain rules of applicable data protection  law; the processing is for direct marketing purposes; and the personal data  have been unlawfully processed. However, there are exclusions of the right to  erasure. The general exclusions include where processing is necessary: for  exercising the right of freedom of expression and information; for compliance  with a legal obligation; or for the establishment, exercise or defence of legal  claims.

9.6 In some circumstances you have the right to restrict the processing of your  personal data. Those circumstances are: you contest the accuracy of the  personal data; processing is unlawful but you oppose erasure; we no longer  need the personal data for the purposes of our processing, but you require  personal data for the establishment, exercise or defence of legal claims; and  you have objected to processing, pending the verification of that objection.  Where processing has been restricted on this basis, we may continue to store  your personal data. However, we will only otherwise process it: with your  consent; for the establishment, exercise or defence of legal claims; for the  protection of the rights of another natural or legal person; or for reasons of  important public interest.

9.7 You have the right to object to our processing of your personal data on  grounds relating to your particular situation, but only to the extent that the  legal basis for the processing is that the processing is necessary for: the  performance of a task carried out in the public interest or in the exercise of  any official authority vested in us; or the purposes of the legitimate interests  pursued by us or by a third party. If you make such an objection, we will  cease to process the personal data unless we can demonstrate compelling  legitimate grounds for the processing which override your interests, rights  and freedoms, or the processing is for the establishment, exercise or defence  of legal claims.

9.8 You have the right to object to our processing of your personal data for direct  marketing purposes (including profiling for direct marketing purposes). If you  make such an objection, we will cease to process your personal data for this  purpose.

9.9 You have the right to object to our processing of your personal data for  scientific or historical research purposes or statistical purposes on grounds  relating to your particular situation, unless the processing is necessary for the  performance of a task carried out for reasons of public interest.

9.10 To the extent that the legal basis for our processing of your personal data is: (a) consent; or

(b) that the processing is necessary for the performance of a contract to  which you are party or in order to take steps at your request prior to  entering into a contract,

and such processing is carried out by automated means, you have the right  to receive your personal data from us in a structured, commonly used and  machine-readable format. However, this right does not apply where it would  adversely affect the rights and freedoms of others.

9.11 If you consider that our processing of your personal data infringes data  protection laws, you have a legal right to lodge a complaint with a  supervisory authority responsible for data protection. In relation to  complaints under EU data protection law, you may do so in the EU member  state of your habitual residence, your place of work or the place of the

 

alleged infringement; in relation to complaints under UK data protection law,  you should do so in the UK.

9.12 To the extent that the legal basis for our processing of your personal data is  consent, you have the right to withdraw that consent at any time. Withdrawal  will not affect the lawfulness of processing before the withdrawal.

9.13 You may exercise any of your rights in relation to your personal data by  written notice to us, in addition to the other methods specified in this Section  9.

12. Updating information

12.1 Please let us know if the personal information that we hold about you needs  to be corrected or updated.

13. Acting as a data processor

13.1 In respect of Job Application data, we do not act as a data controller; instead,  we act as a data processor.

13.2 Insofar as we act as a data processor rather than a data controller, this policy  shall not apply. Our legal obligations as a data processor are instead set out  in the contract between us and the relevant data controller.

14. About cookies

14.1 A cookie is a file containing an identifier (a string of letters and numbers) that  is sent by a web server to a web browser and is stored by the browser. The  identifier is then sent back to the server each time the browser requests a  page from the server.

14.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent  cookie will be stored by a web browser and will remain valid until its set  expiry date, unless deleted by the user before the expiry date; a session  cookie, on the other hand, will expire at the end of the user session, when the  web browser is closed.

14.3 Cookies may not contain any information that personally identifies a user, but  personal data that we store about you may be linked to the information  stored in and obtained from cookies.

15. Cookies that we use

15.1 We use cookies for the following purposes:

(a) authentication and status - we use cookies to identify you when you  visit our website and as you navigate our website, and to help us  determine if you are logged into our website

(c) personalisation - we use cookies to store information about your  preferences and to personalise our website for you

(d) security - we use cookies as an element of the security measures used  to protect user accounts, including preventing fraudulent use of login  credentials, and to protect our website and services generally

(e) advertising - we may use cookies to help us to display advertisements  that will be relevant to you

 

(f) analysis - we use cookies to help us to analyse the use and  performance of our website and services

(g) cookie consent - we use cookies to store your preferences in relation  to the use of cookies more generally

16. Cookies used by our service providers

16.1 Our service providers use cookies and those cookies may be stored on your  computer when you visit our website.

16.2 We use Google Analytics. Google Analytics gathers information about the use  of our website by means of cookies. The information gathered is used to  create reports about the use of our website. You can find out more about  Google's use of information by visiting  

https://www.google.com/policies/privacy/partners/ and you can review  Google's privacy policy at https://policies.google.com/privacy 

16.3 We publish Google AdSense advertisements on our website, together with  advertisements from the following advertisers and advertising networks that  are distributed by Google. The advertisements may be personalised to reflect  your interests. To help determine your interests Google and its partners use  cookies.

The cookies are used to track your previous visits to our website and your  visits to other websites. You can opt out of Google's personalised advertising  by visiting https://www.google.com/settings/ads and you can opt out of third  party cookies use for personalised advertising by visiting  

http://www.aboutads.info. You can review Google's privacy policy at  https://policies.google.com/privacy.

16.4 We use a Facebook pixel on our website. Using the pixel, Facebook collects  information about the users and use of our website. The information is used  to personalise Facebook advertisements and to analyse the use of our  website. To find out more about the Facebook pixel and about Facebook's use  of personal data generally, see the Facebook cookie policy at  

https://www.facebook.com/policies/cookies/ and the Facebook privacy policy  at https://www.facebook.com/about/privacy. The Facebook cookie policy  includes information about controlling Facebook's use of cookies to show you  advertisements. If you are a registered Facebook user, you can adjust how  advertisements are targeted by following the instructions at  

https://www.facebook.com/help/568137493302217.

17. Managing cookies

17.1 Most browsers allow you to refuse to accept cookies and to delete cookies.  The methods for doing so vary from browser to browser, and from version to  version. You can however obtain up-to-date information about blocking and  deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection firefox-desktop (Firefox);

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);

 

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and website-data-sfri11471/mac (Safari); and

(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge browsing-data-and-privacy (Edge).

17.2 Blocking all cookies will have a negative impact upon the usability of many  websites.

17.3 If you block cookies, you will not be able to use all the features on our  website.

18. Cookie preferences

18.1 You can manage your preferences relating to the use of cookies on our  website by visiting: www.voyse.io

19. Amendments

19.1 We may update this policy from time to time by publishing a new version on  our website.

19.2 You should check this page occasionally to ensure you are happy with any  changes to this policy.

19.3 We may notify you of significant changes to this policy by email. 20. Our details

20.1 This website is owned and operated by Voyse Ltd

20.2 We are registered in England and Wales under registration number 08575516 and our registered office is at 1 Newton Court, Kelvin Drive, Knowlhill, Milton  Keynes, MK5 8NH

20.3 Our principal place of business is at 1 Newton Court, Kelvin Drive,  Knowlhill, Milton Keynes, MK5 8NH

20.4 You can contact us:

(a) by post, to the postal address given above.

(b) using our website contact form.

(c) by telephone, on the contact number published on our website; or (d) by email, using the email address published on our website.

22. Representatives

22.1 Our representative within the EU with respect to our obligations under data  protection law is identify representative and you can contact our  representative by email; info@voyse.io

 

22.2 Our representative within the UK with respect to our obligations under data  protection law is Nathan Bendell and you can contact our representative by  info@voyse.io

23. Data protection officer

23.1 Our data protection officer's contact details are: Nathan Bendell.