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Privacy
Policy

Privacy Policy

  1. Introduction and Terms

    Virtual Pricing Director Limited (“We” or “us”) are committed to protecting and respecting your personal data and privacy. This privacy policy relates to our use of any personal data we collect from you in relation to your use of our website (https://www.virtualpricingdirector.com), or where you apply for a job with us. Whenever you provide such information, we are legally obliged to use your information in line with all applicable laws concerning the protection of personal data; including the Data Protection Act 2018 (DPA), and The General Data Protection Regulation 2016 (GDPR) together, and with other subsequent laws "Data Protection Laws".

    For further information about the Personal Data that we collect when you use or interact with our Virtual Pricing Director Product, please see our Product Privacy Notice

  2. Who are we and how to contact us

    For the purpose of the Data Protection Laws, the data controller is Virtual Pricing Director Limited, registered company number 10982080. If you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below:

    Martyn Jennings
    Privacy Officer
    Virtual Pricing Director Limited
    Email: privacy@virtualpricingdirector.com
    Telephone: 07771 778 099

  3. The data we collect about you
    1. We collect and process Personal Data. Typically, the Personal Data we collect, and process will include name, address and email address but we may collect and/or process other Personal Data from time to time. It also may include IP address and cookies of your visit to websites.
    2. We only collect data from you directly or via third parties (see Third Parties below).
  4. How your data will be used
    1. We use information held about you to:
      1. carry out our obligations arising from any contracts entered into between you (or your employer) and us;
      2. provide you with information, products or services that you request from us or which we feel may interest you (where you have consented to be contacted for such purposes or where we have identified a Legitimate Interest);
      3. carry out necessary maintenance to our infrastructure; and
      4. notify you about changes to our services
    2. We also embrace the use of social media and may wish to process any comments made public by you.
  5. Third Parties
    1. We will generally keep your information within the organisation except where disclosure is required or permitted by law, when we use third party service providers (data processors) to supply and support our services to you, or where we have your consent. We may also disclose your Personal Data to any competent law enforcement body, regulatory, government agency, court or other third party where we believe the disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend out legal rights, or (iii) to protect your vital interests or those of any other person. We may also share your Personal Data with an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer that it must not use your personal information only for the purposes disclosed in this privacy policy.
    2. We have contracts in place with our data processors and we have taken appropriate safeguards to ensure that your Personal Data will remain protected in accordance with this privacy policy. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
    3. Please see below the list which sets out the categories of recipients of personal data.

      SERVICE PROVIDED

      IT Providers and Support Services

      Email Provider

      Secure document disposal service

      Internal HR systems provider

      Banks

      Email marketing platforms

      Accountants

      Solicitors
    4. In addition, third party recruitment companies may provide us with Personal Data, and they should only do so where the law allows them to; please see the "Applications to work for us" heading below for more information on this.
  6. Where your data is held

    Your data is stored by us and our processors in the EEA.

  7. Legal basis for processing personal information
    1. Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.
    2. However, we will normally collect Personal Data from you only (i) where we need the Personal Data to perform a contract with you (or your employer), (ii) where the processing is in our Legitimate Interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.
    3. If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you (or your employer), we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).
    4. If we collect and use your Personal Data in reliance on our Legitimate Interests (or those of any third party), this interest will normally be to provide our website and services and for our legitimate commercial interest, for example improving our platform or undertaking marketing. We may have other Legitimate Interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
    5. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "Who we are and how to contact us" heading above.
  8. Legitimate Interest & Marketing
    1. Where we use Legitimate Interests, we will record our decision and our method on making this decision.
    2. If you are an existing contact or customer, we will only contact you by postal and electronic means (e-mail) with information about services or goods which you have previously purchased from us or enquired about. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by post or electronic means only if you have consented to this. You can choose to not receive these types of communication by contacting us.
  9. Applications to work for us

    If you apply to work for us (directly or indirectly) in any role (including volunteers) we may receive data about you (such as your contact details, work history, curriculum vitae, salary expectations and any other information that you choose to make available to us in relation to your employment expectations), including from third party recruitment companies. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.

  10. Data Retention
    1. We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you (or your employer) have requested or to comply with applicable legal, tax or accounting requirements).
    2. When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible. Our data retention policy is dictated by the Data Protection Laws and is available for inspection by submitting a written request using the contact details provided in this policy.
  11. Your Rights
    1. Under the Data Protection Laws your rights are:
      1. To be informed – We must make this privacy policy (sometimes referred to as a privacy notice) available with the emphasis on transparency over how we process your data.
      2. Access – You are entitled to find out what details we may hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. Individuals can find out if we hold any of their Personal Data by making a formal request under the Data Protection Laws. Such requests should be in writing to the contact details provided in this policy. In the instance that we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data, we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy). The information we supply will:
        1. confirm that your data is being processed;
        2. verify the lawfulness and the purpose of the processing;
        3. confirm the categories of personal data being processed;
        4. confirm the type of recipient to whom the personal data have been or will be disclosed; and
        5. let you have a copy of the data in an intelligible form.
      3. Rectification – We are obliged to correct or update your details. We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.
      4. Erasure – This is also known as the request to be forgotten. Under Data Protection Laws you have the right to erasure under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and should be submitted in writing to the contact details provided in this policy.
      5. Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.
      6. Portability – You have the right to obtain and reuse your personal data that you have provided to us.
      7. Object – You have the right to object to us processing your data in relation to direct marketing and or profiling.
      8. Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling.
      9. Consent – if we are processing your Personal Data with your consent, then you can withdraw this consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
    2. Please note that you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by the Data Protection Laws and as summarised above.
    3. If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone
  12. Changes

    We keep our privacy policy under regular review, and you should check back regularly to ensure you are aware of changes to it. We may display this notice to you from time to time to help ensure you are aware of its contents.

  13. Complaints

    You have the right to complain about the processing of your personal data. Please contact us using the details provided above. If you are still unsatisfied you have the right to complain to the Information Commissioners Office.

Cookie Policy

Our site uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By browsing or using the services we provide on the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the memory of your device. Cookies contain information that is transferred to your device’s memory.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Cookie Name Purpose Further Information
Google Analytics _ga Used to distinguish users by Google Analytics. Expires 2 years from set/update.
_dc_gtm   Used to help identify the visitors by either age, gender, or interests by DoubleClick - Google Tag Manager. Expires 24 hours from set/update.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You may block cookies by activating the setting on your browser that allows you to refuse the storage of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.