Effective Date: 03 May 2019
The purpose of this notice
We are committed to protecting your privacy and safeguarding your personal data. Our use of your personal data is subject to the EU General Data Protection Regulation, other relevant UK and EU legislation (together Data Protection Legislation), as well as marketing rules.
In this privacy notice we explain how we will process your personal information obtained through your use of this website, our image collection scanning software, and through other interactions with you (e.g. email communication).
It is important that you read this privacy notice, together with any other privacy notice we may provide on specific occasions, so that you are fully aware of how and why we are using your data, and what data protection rights you have.
What does this notice cover:
- Who we are
- Personal data we collect
- How we collect personal data
- How and why we use personal data
- Who we share personal data with
- How long we keep personal data
- Your rights
- Keeping personal data secure
- How to contact us
- Changes to this privacy notice
Who we are
When we say we, us or our in this privacy notice, we mean Veritent Ltd, a company incorporated and registered in England and Wales with company number 11565374, and whose registered office is at Clavering House, Clavering Place, Newcastle upon Tyne, NE1 3NG.
For the purposes of the Data Protection Legislation, we are the controller of your personal data. This means that we are responsible for deciding how we hold and use personal information about you.
Our Data Protection Officer is Ryan Mottershead. You can contact him at email@example.com.
Personal data we collect
Personal data means information which relates to an identified or an identifiable individual. We may collect and process the following types of personal information:
Types of personal data we may collect
First name; Last name
Financial and transactional data
Payment card details; details of orders made and processed; details of payment received/made; details of invoices received /issued
Interests; preferences; feedback and survey responses; posts and materials uploaded onto your website
Name of business or organisation
Services you signed up to; products/services purchased
Collection of users' images
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.
We do not provide goods/services directly to children or collect their personal data. You have to be at least 18 years old to use our website. However, we may process images depicting children, if you upload them into our website/software.
Before you disclose to us the personal information of another person you must ensure that you have a lawful basis to do so. For information on when and how you can lawfully disclose personal data, please see the Information Commissioner's Office Guide to the General Data Protection Regulation.
We may also collect, use and share anonymised, aggregated data such as statistical or demographic data for any purpose. Anonymised data may be derived from your personal data but is not considered personal information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate information on how you use our website to calculate the percentage of users accessing a specific website feature.
How we collect personal data
We collect most of this information from you direct. However, we may also collect information from other sources.
Type of source
Your use of our website and services
when you sign up to or use our services (e.g. upload images onto our website or app or make payments to us); sign up to our mailing list, complete a contact form; complete a survey; submit feedback
Direct interactions with you
when you first contact us (e.g. by phone or email); when you register interest in our services; when you give us your business card
From publicly accessible sources
we collect URLs of websites where the images which you register with us are used; your website; your profiles on social media platforms (e.g. LinkedIn, Facebook, Twitter, Instagram)
Automated technologies or interactions
How and why we use personal data
Under the Data Protection Legislation, we can only use your personal data if we have a proper reason for doing so.
- Consent. Generally, we do not rely on consent as a legal basis for processing your personal data other than to:
- place cookies and similar tracking technologies on your device for Google Analytics, Hotjar, HubSpot, and MailChimp (please see our Cookies Notice for further details);
- send you our blogs, newsletters or other electronic marketing communication, if you requested or expressly agreed to receive such communication; and
- respond to your enquiries.
Where your permission is required, we will ask you for such consent separately and clearly. You have the right to withdraw consent to marketing at any time by emailing us at firstname.lastname@example.org or using the 'unsubscribe' link in our marketing emails. Even if we are not required to obtain your consent for marketing purposes, you can still opt-out of receiving marketing communications at any time, so you are still in control.
- Contract. We will use your personal data if we need to do it to perform our obligations under a contract with you, or if it is necessary for a contract which we are about to enter with you. For example, if we need to:
- register you as a new customer or administer your account (e.g. set up your subscription and administer invoicing and payments);
- provide our services to you;
- manage our relationship with you (e.g. to respond to your enquires or to notify you about changes to our services and to inform you about updating preferences);
- provide after sale care services (e.g. technical support); and
- enable you to take part in competitions.
- Legitimate interests. We may process your personal data when we (or third party) have a legitimate reason to use it, so long as this is not overridden by your own rights and interests. For example:
- to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
- to manage your account and our relationship with you;
- to manage payments, fees, charges, and to collect debts which you may owe to us;
- to interact with you professionally (e.g. if you represent our client, supplier or business partner);
- to deal with your enquiry unrelated to a contract which we may have with you;
- to provide you with a free service (e.g. a free trial);
- to ask you to leave a review or complete a survey;
- to send you our updates or other electronic marketing communications in respect of similar products or services to those which we had previously supplied to you or which you had previously enquired about;
- to increase our business or promote our brand through delivering relevant website content and advertisements to you and marketing communication;
- to measure or understand the effectiveness of the advertising we provide to you;
- to improve our website, products, services, marketing, and customer relationships and understanding;
- to conduct web and app analytics (using Google Analytics, Hotjar, and HubSpot);
- for the prevention and detection of fraud and spam (using Recaptcha);
- for the establishment, exercise or defence of legal claims.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or structure of our business.
- Legal obligation. We may process your personal data to comply with our legal obligation. For example, to:
- address your complaint; and
- comply with a request from a competent authority.
Who we share personal data with
We may share your information with third parties for the purposes set out in this notice.
As part of our services we allow our registered users to upload, transmit, store and send their content (images, text and videos) through our platform (website and app). If you use our services, such content may be transmitted across various public networks in order to deliver our obligations under our contract with you.
We also share data with providers of cloud-based tools and services, which we use to operate our business:
- Amazon Web Services and DigitalOcean, US companies who provide web and app hosting services to us;
- Google, based in the USA, who provide Google Analytics web and app analytics services to us;
- HubSpot, based in the USA, who provide customer relationship management services to us;
- Hotjar, based in Malta, who provide Hotjar web and app analytics services to us; and
- Rocket Science based in the USA, providers of the MailChimp software, which we use for our email marketing communications.
We impose contractual obligations on the above providers to ensure that your personal data is protected.
Transfers of data outside the European Economic Area (EEA) are subject to special rules under the Data Protection Legislation. Amazon Web Services and DigitalOcean store personal data of EU based individuals in the EU. Those of our providers who are based in the US subscribe to the EU-US Privacy Shield framework. Transfers of personal data to US companies who subscribe to the EU-US Privacy Shield framework are deemed by the European Commission to provide an appropriate level of protection.
We may also:
- disclose your personal data to professional advisers (e.g. lawyers, accountants, auditors or insurers) who provide professional services to us;
- disclose your personal data to certain third parties if specifically requested or agreed with you (e.g. if you ask us to introduce you to a third party);
- disclose and exchange certain information with law enforcement agencies and regulatory bodies to comply with our legal obligations; and
- share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
How long we keep personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. For example, if you subscribe to our updates, we will generally hold your data for that purpose until you unsubscribe or otherwise tell us that you no longer wish to receive such communications.
If you use our services, we will generally keep your data for up to six years after the end of our contract with you in respect of that service. However certain data may be kept by us for a different duration (for example, images which you upload into our website or app which you choose to delete from your account on our platform).
In some circumstances we may anonymise 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.
You have a number of rights in relation to your personal data, which allow you to access and control your information in certain circumstances. You can exercise these rights free of charge, unless your request is manifestly unfounded or excessive (in which case we may charge a reasonable administrative fee or refuse to respond to such 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.
The right to require us to correct any inaccuracies in your personal data.
Erasure (to be forgotten)
The right to require us to delete your personal data in certain situations.
Restriction of processing
The right to require us to restrict processing of your personal data in certain circumstances (e.g. if you contest the accuracy of the data we hold).
The right to receive, in certain situations, the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party.
The right to object at any time to your personal data being processed for direct marketing (including profiling) or, in certain other situations, to our continued processing of your personal data (e.g. processing carried out for the purpose of our legitimate interests).
Not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you, or similarly significantly affects you.
If you would like to exercise any of those rights, please contact us by email at email@example.com or by post at Clavering House, Clavering Place, Newcastle upon Tyne, NE1 3NG. Please let us know what right you want to exercise and the information to which your request relates.
Keeping personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We hope that we can resolve any query or concern you may raise about our use of your information.
The Data Protection Legislation also gives you a right to lodge a complaint with a supervisory authority, in particular in the European Union (or the European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws has occurred. The supervisory authority in the UK is the Information Commissioner, who may be contacted at www.ico.org.uk/concerns, telephone on 0303 123 1113, or by post to: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner's Office, so please contact us in the first instance.
How to contact us
If you have any questions about this privacy notice, (including any requests to exercise your legal rights) please contact us by either:
- email at firstname.lastname@example.org; or
- post to Veritent Ltd Clavering House, Clavering Place, Newcastle upon Tyne, NE1 3NG.
We may change this privacy notice from time to time, when we do we will publish the new version of the policy on our website. We may also inform you via email or post.