This website (the “Website”) is operated and owned by “Venturiq Ltd” (hereinafter referred to as, “Venturiq Ltd”, “we”, “us” or “our”). Venturiq Ltd and its affiliates are committed to protecting and respecting your privacy.
We have been making best efforts to comply with European General Data Protection Regulation (“General Data Protection Regulation”, “GDPR”) as well other with other relevant EU data protection rules.
To be more specific, this Website is compliant with the following national and international legislation with regards to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation (GDPR)
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.
This Website is not intended for children and we do not intentionally collect data relating to children.
This Website may include links to third-party websites, applications or plug-ins. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements, policies or activities.
We may collect from you the following personal data: name, email address, mobile telephone number, computer’s internet protocol (IP) address, your user id in Skype™ or in other social networks and messaging platforms. In cases when you provide us with your personal data or CV, we process and store its content, which may include, without limitation, the following information: full name, contact details, address, education background, professional experience, family status, marital status, nationality, country of residence, date of birth. In the event that we enter into a business relationship with you, which may or may not include payments being made by us to you, or by you to us, we process and store your details which may include bank details, passport details, company details and VAT registration details, according to the needs of the specific business relationship or transaction.
On each occasion that we are process your personal data, we are governed by the following principles:
- personal data is processed lawfully, fairly and in a transparent manner, in relation to you;
- personal data is collected only for specified, explicit and legitimate purposes;
- personal data is always adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
- data held should be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is held is inaccurate, having full regard to the purposes for which it is processed, is erased or rectified without delay.
PURPOSES OF PROCESSING OF PERSONAL DATA
We may process your personal data for a number of different purposes. For each purpose we must have a legal ground for such processing.
Generally such legal grounds fall into the following categories:
- you have given us explicit consent to engage in the processing of your personal data;
- processing of your personal data is necessary for the performance of a contract to which you are a party;
- you requested us to process your personal data prior to entering into a contract;
- processing is necessary for compliance with regards to our legal obligations, to which we are the subject;
- processing is necessary in order to protect your vital interests or the vital interests of another natural person or persons;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority laid upon us as data controller;
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
What do we mean when we say “Legitimate interest” and “Performance of contract”?
Legitimate Interest shall mean our interest as a business in conducting and managing your data. We hereby confirm that 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).
Performance of contract means processing of 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.
We may disclose your personal data, if such disclosure is required or permitted by law.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties may be based outside the European Union (EU) which means that the processing of your personal data will involve a transfer of data outside the EU.
Whenever we transfer your personal data out of the EU, we ensure that at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- where we use certain service providers, we may use specific contracts approved by the European Commission, which give personal data the same protection that it has in the EU;
- where we use providers based in the USA, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between the EU and the USA.
In the event that there is neither an adequacy decision nor appropriate safeguards implemented, we may still transfer your personal data out of the EU under the following circumstances:
- we have informed you about the possible risks of transfers of your personal data and you has explicitly consented to the proposed transfer of your personal data out of the EU;
- the transfer is necessary for the performance of a contract concluded between you and us or if you requested us to perform any pre-contractual measures;
- the transfer is necessary for the conclusion or performance of a contract concluded between us and another natural or legal person for your benefit;
- the transfer is necessary for important reasons of public interest;
- the transfer is necessary for the establishment, exercise or defence of legal claims;
- the transfer is necessary in order to protect your vital interests or interests of other persons in cases where you are physically or legally incapable of giving consent;
Please feel free to contact us in case you wish to procure more information on the specific mechanisms used by us when transferring your personal data outside the EU.
LINKS TO OTHER WEBSITES
This Website may contain links to other websites. Please be informed that we have no liability for your use of any third party websites. You use any third party websites at your own risk. We ask you to read the privacy statements of the other websites you visit to become informed of their practices and policies before using them and we are not responsible for the privacy policies or practices or other websites.
AGE OF CONSENT
YOUR LEGAL RIGHTS
- The right to request access to your personal data. This means that you may request us to send you a copy of the personal data we hold about you and to check that we are lawfully processing it.
- The right to request correction of the personal data. This means that you may request any incomplete or inaccurate data we hold about you to be corrected.
- The right to 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 the processing of it. You have the right to ask us to delete or remove your personal data, where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data in order to comply with any relevant applicable laws. Please note that, on occasion, we may be unable 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.
- The right to object to processing.You may object to processing of your personal data where you know or have grounds to assume that such processing impacts on your fundamental rights and freedoms. Also, where we are processing your personal data for direct marketing purposes, you have the right to object to processing of your data at any time. We may demonstrate that we are processing your data due to legitimate grounds which in certain circumstances override your rights and freedoms to object to processing of your data.
- The right to request restriction of processing of personal data. You may request us to suspend the processing when you want us to make the processed data accurate; or the processing of data is unlawful, but you do not want us to erase it; or if 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; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use, store or process it.
- The right to request the transfer of your personal data to you or to third parties.Upon your request, we will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to data which is processed by automated means and only in cases where you provided us with the relevant explicit consent to such processing or processing is used in the course of the performance of a contract.
- The right to withdraw consent at any time. You may withdraw your consent to the processing of your personal data at any time, without affecting the lawfulness of processing, based on consent, before its withdrawal.
Venturiq Ltd will keep your personal data only as long as it is necessary to fulfil the purposes that the personal data was collected for, including (without limitation) the purposes of compliance with any relevant reporting, accounting or legal requirements.
When determining how long your personal data will be kept with us, we consider the following factors: nature, sensitivity of the personal data and its amount; the potential risk of harm from unauthorised use or disclosure of your personal data; the purposes for which we collected your personal data and processed it; applicable legal requirements.
Where we are processing your personal data for marketing purposes, we may contact you as frequently as every month, in order to ensure you that you are happy to continue receiving our marketing communications. You may require us not to use your personal data for marketing purposes, or object to such processing at any time by sending appropriate requests or a statement to our email address.
In some circumstances, we may anonymise and/or pseudonymize your personal data for statistical research purposes. In such cases your personal data will no longer be associated with you and we may use it indefinitely without further notice to you.
REQUEST FOR INFORMATION
Sometimes we may need to request specific information from you in order to 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 that we have in place to ensure that personal data is not disclosed to any person, that 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.
We will report any unlawful data breach of this Website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach, or within 72 hours of us coming to know about the breach, if it is apparent that personal data stored in an identifiable manner has been stolen.
In the UK, data breaches are to be reported to the Information Commissioner’s Office, in the first instance.
TIME LIMIT TO RESPOND
We will make our best efforts to respond to all of your legitimate requests within 1 (one) month. Sometimes, it may take us longer than a 1 (one) month, if your request is particularly complex or you have made a number of requests. In such cases, we will notify you and keep you updated.
You have the right to lodge a complaint with a data protection authority, in particular in the state or country of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of your personal data infringes the applicable Data Protection Law.
However, we would appreciate the possibility to deal with your concerns before you send your complaint to a supervisory authority, so please contact us in the first instance.
QUESTIONS AND CONTACT INFORMATION